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GOVERNMENT SERVICE INSURANCE SYSTEM v. CIVIL SERVICE COMMISSION

FACTS:

In May 1981, six employees of the Government Service Insurance System (GSIS) were dismissed for their alleged involvement in irregularities during the canvass of supplies and materials. The basis for their dismissal was the Civil Service Law in relation to LOI 14-A and/or LOI No. 72. The employees filed a Motion for Reconsideration, but it was denied.

Five of the dismissed employees then appealed to the Merit Systems Board, which found the dismissals to be illegal. The Merit Systems Board determined that formal charges had not been filed against the employees and that they were not given an opportunity to answer the allegations. As a result, the cases were remanded to the GSIS for appropriate disciplinary proceedings.

Displeased with the decision of the Merit Systems Board, the GSIS appealed to the Civil Service Commission. The Civil Service Commission ruled that the dismissals were indeed illegal and ordered the reinstatement of the employees. Furthermore, the Commission directed the GSIS to pay the employees back salaries and benefits.

The GSIS, being dissatisfied with the ruling of the Civil Service Commission, filed an appeal with the Supreme Court. However, the Supreme Court affirmed the ruling of the Commission, albeit with a modification. The modification stated that payment of back salaries would be postponed until the outcome of the disciplinary proceedings was known. Additionally, three of the employees were ordered to be reinstated, while the other two employees had already passed away.

Subsequently, the heirs of the deceased employees filed a motion for the execution of the Civil Service Commission Resolution. The GSIS opposed this motion, arguing that the resolution was superseded by the Supreme Court's resolution. Nevertheless, the Civil Service Commission granted the motion for execution and directed the GSIS to pay the heirs of the deceased employees.

Unsatisfied with the decision of the Civil Service Commission, the GSIS filed a motion for reconsideration, which was ultimately denied. As a final attempt, the GSIS filed a petition for certiorari with the Supreme Court, asserting that the Civil Service Commission lacked jurisdiction in executing its judgments and that the writ of execution was invalid for modifying the Supreme Court's resolution.

ISSUES:

  1. Whether the Civil Service Commission has the power to execute its judgments and final orders or resolutions.

  2. Whether the writ of execution issued by the Commission in this case is void because it varies the Supreme Court's resolution of July 4, 1988.

RULING:

  1. Yes, the Civil Service Commission has the power to execute its judgments and final orders or resolutions. The Commission, as a constitutional commission, is invested with quasi-judicial powers and has the authority to hear and decide administrative disciplinary cases. It is also granted the power to promulgate its own rules concerning pleadings and practice before it or before any of its offices, as long as these rules do not diminish, increase, or modify substantive rights.

  2. No, the writ of execution issued by the Commission is not void because it varies the Supreme Court's resolution. The July 4, 1988 resolution modified the Commission's resolution of October 21, 1987 by eliminating the payment of back salaries to the dismissed employees until the outcome of the disciplinary proceedings is known. The Commission's writ of execution, which directed the payment of back salaries to the heirs of the deceased employees, is not a violation of the Supreme Court's resolution as it is consistent with the Commission's power to execute its own judgments and final orders.

PRINCIPLES:

  • The Civil Service Commission, as a constitutional commission, has quasi-judicial powers and the authority to hear and decide administrative disciplinary cases.

  • The Commission has the power to execute its judgments and final orders or resolutions.

  • The Commission has the power to promulgate its own rules concerning pleadings and practice, as long as these rules do not diminish, increase, or modify substantive rights.