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DEPARTMENT OF TRANSPORTATION v. ROLANDO S. CRUZ

FACTS:

The case revolves around the request of the Department of Transportation and Communications (DOTC) Secretary to the Civil Service Commission (CSC) to convert four Department Legislative Liaison Specialist (DLLS) positions to permanent status. The CSC granted the request but clarified that the incumbents of the DLLS positions had no vested right to automatically occupy the permanent positions. A series of resolutions and letters were exchanged between the DOTC and the CSC, with the latter initially ruling that the incumbents were appointed to the permanent positions. However, the CSC later modified the resolution, stating that the previous incumbents were no longer employees.

Erneliza Mamaril and Rolando Cruz, the incumbents, filed a motion for reconsideration with the CSC, which was granted, reinstating them to their former positions. The DOTC filed a motion for reconsideration challenging the back salaries awarded to Mamaril and Cruz, but the CSC denied the motion and held that they were not entitled to back salaries.

Mamaril filed a separate petition, but it was dismissed due to lack of verification and certification against forum shopping. On the other hand, Cruz's petition was granted by the Court of Appeals (CA), ordering the DOTC to pay him back salaries. The DOTC filed a motion for reconsideration, which the CA denied. Consequently, the DOTC filed a petition for review with the Supreme Court, raising arguments of good faith, application of the Octot v. Ybañez case, and the rule that a public official is not entitled to compensation if no services were rendered.

ISSUES:

  1. Whether a government employee who was dismissed from service in good faith is entitled to back salaries upon his reinstatement.

  2. Whether the ruling in Octot v. Ybañez applies in this case.

  3. Whether the termination of the petitioner's services was attended with bad faith and/or grave abuse of discretion.

  4. Whether the doctrine of stare decisis applies to the present case.

RULING:

  1. The Court of Appeals erred in not applying the rule that a public official is not entitled to any compensation if he has not rendered any services. The general proposition is that a public official is not entitled to any compensation if he has not rendered any service. Compensation is paid only for service actually or constructively rendered. Therefore, a government employee who was dismissed from service in good faith is not entitled to back salaries upon his reinstatement.

  2. The ruling in Octot v. Ybañez applies in this case. The determination of the award of back salaries upon reinstatement of a government employee depends on the good faith or bad faith and grave abuse of discretion in the dismissal or termination of their services. If a government employee was dismissed or terminated in bad faith or with grave abuse of discretion, they may be entitled to back salaries. However, if there is no proof of bad faith and/or grave abuse of discretion, the employee is not entitled to backwages and cannot claim for damages.

  3. The termination of the petitioner's services was not attended with bad faith and/or grave abuse of discretion. The Court found that the Department of Transportation and Communications (DOTC) terminated the petitioner's services in accordance with the resolution of the Civil Service Commission (CSC), which was found to be legal and valid.

  4. The doctrine of stare decisis applies to the present case. The Court held that the previous ruling in a case, Mamaril v. DOTC, which involved the same facts as the present case, is binding and applicable. Under the doctrine of stare decisis, when the Supreme Court has once laid down a principle of law as applicable to a certain state of facts, it will adhere to that principle and apply it to all future cases with substantially the same facts, regardless of whether the parties and property are the same. Thus, the Court upheld the previous ruling and applied it to the present case.

PRINCIPLES:

  • A public official is not entitled to any compensation if they have not rendered any services.

  • Compensation is paid only for service actually or constructively rendered.

  • The determination of the award of back salaries upon reinstatement depends on the good faith or bad faith and grave abuse of discretion in the dismissal or termination of the services of a government employee.

  • In the absence of proof of bad faith and/or grave abuse of discretion, a government employee is not entitled to backwages and cannot claim for damages.

  • Stare Decisis: The doctrine of stare decisis is a judicial practice that when a court has laid down a principle of law as applicable to a certain state of facts, it will adhere to that principle and apply it to all future cases with substantially the same facts. This policy is grounded on the necessity for securing certainty and stability of judicial decisions. Under the doctrine, once a case has been decided one way, any other case involving exactly the same point at issue should be decided in the same manner, unless there are powerful countervailing considerations.