GR 92490; (July, 1990) (Digest)
G.R. No. 92490 July 30, 1990
MELANIO N. ESQUIG, petitioner, vs. CIVIL SERVICE COMMISSION and EDNA D. FERRER, respondents.
FACTS
The petitioner, Melanio Esquig, and the private respondent, Edna Ferrer, both applied for the vacant position of Records Officer IV in the Register of Deeds office in Lingayen, Pangasinan. The Secretary of Justice appointed Ferrer to the position in October 1987. Esquig protested this appointment to the Merit Systems Promotion Board (MSPB) of the Civil Service Commission, which ruled in his favor on January 18, 1989, and denied Ferrer’s motion for reconsideration on May 12, 1989.
Ferrer subsequently appealed the MSPB decision to the Civil Service Commission (CSC). On November 21, 1989, the CSC reversed the MSPB and upheld Ferrer’s appointment. The CSC ruled that since both candidates possessed the required qualifications and neither was the official “next-in-rank” to the vacant position, the appointing authority had the discretion to choose whom it deemed best qualified. Consequently, Esquig, not being the next-in-rank employee, was found to lack the legal personality to protest the appointment.
ISSUE
The sole issue raised is whether the Civil Service Commission had jurisdiction to review and reverse the decision of the Merit Systems Promotion Board, considering Ferrer’s alleged failure to furnish Esquig a copy of her appeal and the timeliness of that appeal.
RULING
The Supreme Court upheld the jurisdiction and decision of the Civil Service Commission. On the procedural matter, the Court found that the CSC correctly did not strictly adhere to legal technicalities, such as the alleged failure to furnish a copy of the appeal, as administrative bodies are not bound by the rigid procedural requirements of the Rules of Court. Jurisprudence supports the principle that such technicalities should not hinder the resolution of cases on their merits, provided both parties are afforded an opportunity to be heard, which they were.
Regarding the timeliness of the appeal, the Court deferred to the CSC’s factual finding that Ferrer received the MSPB’s denial of her motion for reconsideration on May 30, 1989, and filed her appeal to the CSC on June 5, 1989, which was well within the 15-day reglementary period. Factual findings of administrative agencies, when supported by evidence, are accorded respect and are presumed correct. The Court affirmed that the appointing authority’s discretion in promotional appointments, where neither candidate is next-in-rank, is broad and should not be disturbed absent grave abuse of discretion, which was not present here. The petition was denied for lack of merit.