G.R. No. L-62133 September 30, 1986
EDITHA L. LIRA, petitioner, vs. HON. CIVIL SERVICE COMMISSION and BRENDA JARANILLA, respondents.

FACTS

The case involves a dispute over the position of City Budget Officer of Iloilo City. Petitioner Editha L. Lira, originally a Barangay Field Coordinator, was detailed to a budget division and was subsequently appointed as Budget Officer on February 1, 1980, under the city’s newly adopted Position Classification and Pay Plan (PCPP). Private respondent Brenda R. Jaranilla was the Chief of the Budget Operations Division in the City Treasurer’s Office, a position reclassified to Internal Auditor under the same PCPP, to which she was appointed on February 18, 1980. Later, petitioner received a Notice of Salary Adjustment for the Budget Officer position. Jaranilla protested this adjustment, arguing that Lira’s appointment was not made pursuant to Presidential Decree No. 1375, which governed the creation of local budget offices, and that she (Jaranilla) was more qualified. The Civil Service Regional Office dismissed the protest, but the Merit System Board and, on appeal, the Civil Service Commission, ruled in favor of Jaranilla, declaring Lira’s salary adjustment void and ordering Jaranilla’s appointment as City Budget Officer.

ISSUE

The primary issue is whether the Civil Service Commission acted with grave abuse of discretion in nullifying the salary adjustment for petitioner Lira and ordering the appointment of private respondent Jaranilla as City Budget Officer.

RULING

The Supreme Court dismissed the petition, upholding the Civil Service Commission’s resolution. The legal logic centered on the proper implementation of Presidential Decree No. 1375 and its implementing Letter of Instruction (LOI) No. 1039, which mandated the creation of a local budget office and the transfer of qualified personnel from the existing local budget staff. The Court found that the position of City Budget Officer must be filled in accordance with these specific laws, not merely under a general position classification plan. The Commission correctly determined that Jaranilla, as the former Chief of the Budget Operations Division—which constituted the local budget staff under P.D. 477—was the personnel intended to be transferred to the new Budget Office upon its proper creation. Her qualifications, including being a CPA with over six years of direct budgeting experience, exceeded the minimum three-year requirement and surpassed Lira’s approximately two years of relevant experience at the time of the protest. The Court also noted that the city mayor had not complied with the reporting requirement to the Budget Minister for the formal creation of the local budget office as per LOI No. 1039. Consequently, Lira’s appointment and subsequent salary adjustment, not being made under the correct statutory framework, were invalid. The defense of estoppel against Jaranilla for accepting the Internal Auditor position failed, as the legitimate City Budget Office under P.D. 1375 was not yet formally established when she accepted her reclassified role.