G.R. No. 166547 ; September 12, 2007
UMBRA M. TOMAWIS, petitioner, vs. ATTY. NORA M. TABAO-CAUDANG, respondent.

FACTS

Atty. Nora Caudang was appointed as permanent Regional Director of the Office of Muslim Affairs (OMA) in 1987. In 1991, the position was reclassified as a Career Executive Service (CES) position. In 1993, she was replaced by Umbra Tomawis via a presidential appointment. Caudang sought relief from the Civil Service Commission (CSC), which issued Resolution No. 94-0014 in 1994, declaring her appointment permanent and the lawful incumbent. Based on this, she filed a petition for quo warranto with the Court of Appeals (CA), which initially ruled in her favor but later reversed itself in an Amended Decision, dismissing the petition for forum shopping. This Amended Decision became final. Subsequently, in 2002, a new OMA Executive Director reinstated Caudang via an office order, citing the CSC Resolution. Tomawis then filed an action for injunction and prohibition with the Regional Trial Court (RTC), which ruled in his favor, ordering the enforcement of the office order to cease.

ISSUE

Whether the RTC committed grave abuse of discretion in granting the writ of injunction and prohibition, thereby preventing Caudang’s reinstatement based on the OMA Executive Director’s order.

RULING

Yes, the RTC committed grave abuse of discretion. The Supreme Court ruled that the RTC’s injunction was improperly issued as it interfered with a purely administrative act within the Executive Department’s discretion. The power to appoint and remove OMA officials is vested in the President and, by delegation, in the Department Secretary and the OMA Executive Director. The 2002 Office Order reinstating Caudang was a valid exercise of this administrative prerogative. The RTC’s injunction effectively nullified this executive act without legal basis, as the courts cannot control or set aside the exercise of discretion by an administrative officer in the absence of grave abuse of authority. Furthermore, the finality of the CA’s Amended Decision, which dismissed Caudang’s quo warranto petition on procedural grounds, did not invalidate the underlying CSC Resolution declaring her the rightful incumbent. That resolution remained a valid administrative determination that the Executive Director could legally act upon. The RTC’s order, which restrained the implementation of a lawful administrative directive, constituted an unwarranted judicial intrusion into executive functions and was thus issued with grave abuse of discretion.