G.R. No. 197792, December 9, 2015
Civil Service Commission, Petitioner, vs. Madlawi B. Magoyag, Respondent

FACTS

Respondent Madlawi B. Magoyag filed a petition with the Regional Trial Court (RTC) of Lanao del Sur for the correction of his date of birth from July 22, 1947 to July 22, 1954. The RTC granted the petition on November 20, 2007, ordering the Government Service Insurance System (GSIS) and the Bureau of Customs to correct the entry. The RTC amended its decision on June 2, 2008, to also direct the Local Civil Registrar and the Civil Service Commission (CSC) to effect the correction. Respondent, then Deputy Collector of the Bureau of Customs, requested the CSC Regional Office to correct his date of birth in his employment records, submitting supporting documents including his NSO certificate of live birth and the RTC decision. He claimed the discrepancy arose from a mistake in his 1974 employment application with Amanah Bank. The CSC denied his request via Resolution No. 090987 (July 7, 2009), stating the RTC decision was not yet final and executory. Respondent filed a motion for reconsideration, attaching a Certificate of Finality of Judgment from the RTC, but the CSC denied it via Resolution No. 100491 (March 16, 2010). Respondent then filed a Petition for Review under Rule 43 of the Rules of Court with the Court of Appeals (CA). The CA granted the petition and directed the CSC to comply with the RTC decision. The CSC’s motion for reconsideration was denied.

ISSUE

1. Whether the CSC Resolutions (Nos. 090987 and 100491) are reviewable under Rule 43 of the Rules of Court.
2. Assuming they are reviewable, whether the CA erred in ordering the CSC to comply with the RTC decision.

RULING

1. Yes, the CSC Resolutions are reviewable under Rule 43. The Supreme Court held that the CSC was exercising its quasi-judicial function when it issued the assailed resolutions. A quasi-judicial function involves investigating facts, holding hearings, drawing conclusions, and exercising discretion of a judicial nature to adjudicate rights. Although the CSC argued its resolutions were mere administrative responses to a request and involved no hearings, the Court found that by evaluating the evidence submitted (the RTC decision and supporting documents) and making a discretionary determination to deny the request based on its interpretation of the finality of the judgment, the CSC was performing an act of adjudication. Its resolutions determined the legal rights of the respondent regarding the correction of his records. Therefore, these resolutions, issued in the exercise of its quasi-judicial function, were properly appealed to the CA via Rule 43.
2. No, the CA did not err in ordering the CSC to comply with the RTC decision. The Supreme Court affirmed the CA’s decision. The RTC, in a special proceeding for correction of entry under Rule 108 of the Rules of Court, had already rendered a final and executory judgment ordering the correction. The CSC, as a government agency, is bound by such final judgments of courts. The CSC’s refusal to correct the records based on its own assessment of the judgment’s finality, despite the respondent submitting a Certificate of Finality, was an error. The proper course for the CSC was to comply with the final order. The Court emphasized that the CSC cannot review, reverse, or set aside the final judgment of the RTC. Consequently, the CSC was directed to comply with the RTC’s amended decision dated June 2, 2008.
DISPOSITIVE:
The petition is DENIED for lack of merit. The Decision dated May 12, 2011, and the Resolution dated July 22, 2011, of the Court of Appeals are AFFIRMED.