GR 176162; (October, 2012) (Digest)
G.R. No. 176162 & 178845; October 9, 2012
CIVIL SERVICE COMMISSION and ATTY. HONESTO L. CUEVA, Petitioners, vs. COURT OF APPEALS, DR. DANTE G. GUEVARRA and ATTY. AUGUSTUS F. CEZAR, Respondents.
FACTS
Respondents Dr. Dante G. Guevarra and Atty. Augustus F. Cezar were the Officer-in-Charge/President and Vice President for Administration, respectively, of the Polytechnic University of the Philippines (PUP). Petitioner Atty. Honesto L. Cueva, then PUP Chief Legal Counsel, filed an administrative complaint directly with the Civil Service Commission (CSC) against them. The charges stemmed from Guevarra’s alleged falsification of a public document—an Application for Bond—wherein he denied having any criminal or administrative records despite having pending cases before the Sandiganbayan, which Cezar endorsed.
The CSC assumed jurisdiction, issued a formal charge, and placed Guevarra under preventive suspension. Guevarra and Cezar challenged the CSC’s jurisdiction via a petition for certiorari before the Court of Appeals (CA). The CA granted the petition, ruling that the PUP Board of Regents, as the disciplining authority under its charter and the Administrative Code, had exclusive original jurisdiction. The CA further held that Cueva failed to exhaust administrative remedies by not first filing the complaint with the Board.
ISSUE
Whether the Civil Service Commission has original concurrent jurisdiction to directly take cognizance of an administrative complaint filed by a fellow government employee against officials of a chartered state university.
RULING
Yes, the Supreme Court reversed the CA and reinstated the CSC’s resolutions. The Court held that the CSC possesses original concurrent jurisdiction over administrative cases against officials of chartered state universities, even when filed directly with it. This authority is derived from Section 47, Chapter 7, Subtitle A, Title I, Book V of the Administrative Code of 1987 (Executive Order No. 292).
The legal logic is anchored on the CSC’s constitutional mandate as the central personnel agency of the government. While the governing board of a state university (like the PUP Board of Regents) has primary disciplinary authority under its charter ( R.A. No. 8292 ), this jurisdiction is not exclusive but concurrent with the CSC. The law grants heads of agencies the power to investigate and decide cases involving their subordinates, but it does not divest the CSC of its own original jurisdiction. The CSC’s jurisdiction is complementary and serves as a check to ensure uniform application of civil service laws. The Court clarified that the doctrine of exhaustion of administrative remedies was misapplied; it is not a jurisdictional requirement but a condition precedent for judicial review and does not bar the CSC from initially taking cognizance of a complaint. Therefore, the CSC correctly assumed jurisdiction over the complaint filed directly by Cueva, a fellow government employee.