G.R. No. 192584 July 12, 2016
HAMBRE J. MOHAMMAD, Petitioner, vs. GRACE BELGADO-SAQUETON, in her capacity as Director IV, Civil Service Commission, Regional Office No. XVI, Respondent.

FACTS

Petitioner Hambre J. Mohammad was appointed as Provincial Agrarian Reform Officer II (PARO II) in the DAR-ARMM under a temporary status due to his lack of Career Service Executive Eligibility (CSEE) or Career Executive Service (CES) eligibility. On October 24, 2005, he requested a change of his appointment status from temporary to permanent, invoking an RTC decision in a different case concerning division superintendents. Respondent Grace Belgado-Saqueton, Director IV of the Civil Service Commission Regional Office No. XVI (CSCRO No. XVI), denied the request, stating the RTC decision was binding only on its parties and that the PARO II position required CES or CSEE eligibility. Instead of appealing the denial to the Civil Service Commission proper, petitioner filed a special civil action for mandamus before the Regional Trial Court (RTC), arguing the issue was a purely legal question, thus excusing exhaustion of administrative remedies. During the pendency of the case, the Office of the Regional Governor appointed petitioner to the same position with a permanent status. The RTC granted the petition for mandamus and ordered respondent to approve the permanent status. The Court of Appeals reversed the RTC, ruling petitioner failed to exhaust administrative remedies.

ISSUE

Whether the filing of a petition for mandamus with the RTC was proper despite the availability of an administrative remedy against the unfavorable Decision of the Civil Service Commission Regional Office No. XVI.

RULING

No. The Supreme Court affirmed the Court of Appeals Decision. The failure of petitioner to exhaust available administrative remedies was fatal to his cause. The Court held that before seeking judicial intervention, parties must avail themselves of all administrative processes. The issue raised by petitioner was not a purely legal question that would excuse non-exhaustion. Doubt arose as to the truth or falsity of the alleged fact that no position in the ARMM had been declared a CES position, especially after respondent presented Qualification Standards showing the PARO II position was a third-level position requiring CES or CSEE. This invited a review of evidence, making it a question of fact. Furthermore, at the time of filing the mandamus petition, petitioner had no appointment to a permanent position, so he lacked a clear legal right to compel respondent. The Civil Service Commission is the sole arbiter of civil service controversies, and the doctrine of exhaustion of administrative remedies is a cornerstone of the judicial system, allowing agencies to function within their specialized competencies. The Petition for Review was denied.