G.R. No. 168780; November 23, 2007
BACOLOD CITY WATER DISTRICT, Petitioner, vs. JUANITO H. BAYONA, Respondent.
FACTS
Respondent Juanito H. Bayona, a division manager of petitioner Bacolod City Water District (BACIWA), reached the age of 60 in May 1994. The existing Collective Bargaining Agreement (CBA) set compulsory retirement at age 60, but the Civil Service Law provided for retirement at age 65. BACIWA’s Board extended Bayona’s service conditionally until December 1995 but later amended this to retire him effective November 30, 1995. Bayona, seeking to complete 15 years of service for full benefits under PD 1146, had previously requested a ruling from the Civil Service Commission (CSC) on the applicable retirement age.
On January 16, 1996, the CSC officially replied, stating that the compulsory retirement age of 65 under civil service laws prevailed over the CBA. Armed with this ruling, Bayona requested reinstatement from BACIWA, which was denied. He then formally sought relief from the CSC, which, without notifying BACIWA of this specific letter, later issued a resolution ordering his reinstatement with back wages. BACIWA appealed, arguing it was denied due process as it was not notified of Bayona’s reinstatement request to the CSC.
ISSUE
Whether the Civil Service Commission denied BACIWA its right to due process by failing to notify it of Bayona’s letter-request for reinstatement, and whether the CSC correctly ordered Bayona’s reinstatement with back salaries.
RULING
The Supreme Court ruled against BACIWA, affirming the CSC and Court of Appeals. On due process, the Court held that BACIWA was not denied its right. The core issue—the applicable retirement age—had already been squarely settled by the CSC in its January 1996 opinion issued directly in response to Bayona’s query, a copy of which was furnished to BACIWA. This opinion was a definitive ruling that the civil service age of 65 governed. Bayona’s subsequent letter was merely a request for the execution and implementation of that final ruling. BACIWA cannot claim ignorance of the legal basis for the claim, as the operative ruling was already in its possession.
On the merits, the Court upheld the CSC’s application of the civil service retirement age. Following the precedent in Davao Water District v. CSC, water districts and their employees are governed by civil service laws. While a tripartite committee allowed existing CBAs to run their course, the provision on retirement age involved a matter of public policy dictated by statute (PD 1146). The legal retirement age of 65 could not be bargained away. Therefore, Bayona’s retirement at age 60 was illegal. Consequently, his reinstatement and the payment of back salaries from the date of illegal termination until his valid retirement at age 65 in May 1999 were proper, pursuant to the CSC’s Revised Uniform Rules on Administrative Cases.
