G.R. No. L-35078 October 23, 1973
LEVY D. MACASIANO, petitioner, vs. EPI REY PANGRAMUYEN, MARIO R. GOMEZ, EDUARDO S. DE GUZMAN, MELCHOR DE LA CRUZ, and BARBA MARAYAG, respondents.

FACTS

On November 10, 1971, former Cavite City Mayor Fidel D. Dones appointed respondent Mario R. Gomez as Chief of Police. Subsequently, on January 14, 1972, the new City Mayor, Manuel Rojas, terminated Gomez’s services upon finding that Gomez lacked the mandatory military service qualification required under Section 10 of the Police Act of 1966 (Republic Act No. 4864). On the same day, Mayor Rojas appointed petitioner Levy D. Macasiano as the new Chief of Police, and Macasiano immediately took his oath.
The Police Commission, the specialized agency tasked with administering the Police Act, reviewed the matter. In an indorsement dated January 25, 1972, its Chairman, General Crispino M. de Castro, formally notified the Civil Service Commission that Gomez was statutorily disqualified due to his lack of military or police service. The Police Commission requested a re-examination of the Civil Service’s prior attestation of Gomez’s appointment and later endorsed Macasiano’s appointment for attestation. Despite this, the respondent Civil Service Commissioner, perhaps influenced by Gomez’s claim that his basic ROTC training sufficed as military service, recommended the payment of Gomez’s salary and effectively upheld his appointment, leading Mayor Eduardo S. de Guzman to terminate Macasiano.

ISSUE

Whether the Civil Service Commission is bound by the Police Commission’s factual determination and interpretation regarding the statutory qualifications for the position of Chief of Police under the Police Act of 1966.

RULING

Yes. The Supreme Court ruled in favor of petitioner Macasiano, granting the writs of certiorari and quo warranto. The legal logic rests on the principle of administrative autonomy and statutory construction. The Police Act of 1966 created the Police Commission as a specialized body with explicit jurisdiction over the administration and appointment of local police forces, including the power to determine compliance with statutory qualifications like the military service requirement.
The Court held that where the law confers specific jurisdiction upon a specialized agency, its factual findings and interpretations within its expertise must be accorded respect and finality, absent any showing that such determinations are contrary to law. The Civil Service Commission, in its general administrative capacity, cannot simply disregard a specific, formal finding of disqualification made by the Police Commission. Respondent Gomez’s completion of a basic ROTC course was correctly deemed insufficient by the Police Commission to meet the “military service” qualification mandated by law. Policy considerations further support this ruling, as allowing the Civil Service to override the Police Commission would undermine the integrated police reform system envisioned by the Police Act. Consequently, the respondent Commissioner’s action was declared null and void, and Macasiano was upheld as the rightful Chief of Police.