G.R. No. 251903 , January 27, 2025
VICTORIA M. LABASTIDA, PETITIONER, VS. MONINA C. QUIRES, RESPONDENT.

FACTS

The case stemmed from an administrative complaint filed by respondent Monina C. Quires against petitioner Victoria M. Labastida, then Municipal Planning and Development Officer of Saint Bernard, Southern Leyte, for gross neglect of duty and conduct prejudicial to the best interest of the service. After the complaint was initially dismissed by the Civil Service Commission (CSC) due to procedural defects, it was re-filed. On June 10, 2016, the Disciplining Authority (Municipal Mayor) rendered a Decision finding Labastida guilty and meting the penalty of dismissal. A copy of this Decision was sent to Labastida via registered mail, as evidenced by a Registry Return Receipt bearing the annotation “refused to accept 06-14-16.” Labastida filed a Notice of Appeal on March 16, 2017, alleging she received a copy of the Decision only on March 8, 2017. The CSC dismissed her appeal for being filed out of time, reckoning the 15-day appeal period from June 14, 2016. The Court of Appeals affirmed the CSC’s dismissal, applying the presumption of regularity in the performance of official duties by postal officers based on the registry return receipt. Labastida filed a Petition for Review on Certiorari, arguing the reckoning date should be March 8, 2017, and that the presumption of regularity should not apply.

ISSUE

Whether the Court of Appeals erred in ruling that Labastida’s appeal was filed out of time, specifically, whether the registry return receipt alone sufficiently proves service of the June 10, 2016 Decision to start the reckoning of the appeal period.

RULING

The Supreme Court granted the petition. The registry return receipt alone is not sufficient proof of service by registered mail. For service by registered mail to be proven, the registry return receipt must be accompanied by an affidavit of the person mailing stating the facts showing compliance with service requirements (e.g., proper addressing, prepayment, and deposit in the post office). The disputable presumptions that postal officers regularly performed their duties or that letters duly directed and mailed were received in the regular course of mail do not apply in the face of evidence to the contrary. In this case, aside from the annotated return receipt, no other evidence was presented to prove that the Decision was properly addressed, prepaid, and actually mailed. Labastida’s consistent assertion that she received the Decision only on March 8, 2017, and the lack of official records of the Decision in the Office of the Municipal Mayor, contradict the presumption. Therefore, the reckoning period for filing the appeal should be from March 8, 2017, making her appeal timely filed. The Court remanded the case to the CSC for resolution of the appeal on its merits.