Friday, May 1, 2020
Appeals in civil service cases; rule of procedural liberality applied. - When substantial justice dictates it, procedural rules may be relaxed in order to arrive at a just disposition of a case. The purpose behind limiting the period of appeal is to avoid unreasonable delay in the administration of justice and to put an end to controversies. A one-day delay as in this case, does not justify denial of the appeal where there is absolutely no indication of intent to delay as in this case, does not justify denial of the appeal where there is absolutely no indication of intent to delay justice on the part of Paler and the pleading is meritorious on its face.
DAVAO CITY WATER DISTRICT REPRESENTED BY ITS GENERAL MANAGER, RODORA N. GAMBOA, Petitioner, vs. RODRIGO L. ARANJUEZ, et al., Respondents. EN BANC, G.R. No. 194192, June 16, 2015.
"Though the appeal before the CSC lacked a notice of appeal as required by CSC Resolution No. 991936 or the Uniform Rules on Administrative Cases in the Civil Service (URACCS),27 the Consolidated Memorandum filed by the private respondents was enough to be considered as a sufficient compliance with the rules. The Memorandum delineates the errors asserted against DCWD and the discussions supporting their arguments. We find merit in the sufficiency of the Memorandum rather than strict compliance in view of the constitutional right of every employee to security of tenure. A more relevant consideration of public interest is accorded whenever the merits of a case collide with rigid application of the rules.28
Further, we find that the Civil Service Commission, the agency directly concerned, the ruling of which was upheld by the Court of Appeals on review, correctly exercised jurisdiction over respondent’s appeal from the decision of petitioner DCWD, thereby ruling against, if sub silentio, the argument of petitioner that the appeal should be dismissed for lack of proof of payment of appeal. The Civil Service Commission and the Court of Appeals considered the procedural issue raised by petitioner as a surmountable bar to the resolution of the main issue of respondents’ constitutional right to free expression29 as amplified with specificity by their guaranteed right as workers to peaceful concerted activity and their entitlement to security of tenure.30 The decisions of the Civil Service Commission and the Court of Appeals are squarely supported by Adalim v. Taniñas31 stating that:
In a number of cases, we upheld the CSC’s decision relaxing its procedural rules to render substantial justice. The Revised Rules on Administrative Cases in the Civil Service themselves provide that administrative investigations shall be conducted without strict recourse to the technical rules of procedure and evidence applicable to judicial proceedings. The case before the CSC involves the security of tenure of public employees protected by the Constitution. Public interest requires a resolution of the merits of the appeal instead of dismissing the same based on a rigid application of the CSC Rules of Procedure. Accordingly, both the CSC and the CA properly allowed respondent employees’ appeal despite procedural lapses to resolve the issue on the merits.
In Republic of the Philippines v. Court of Appeals,32 this Court pronounced that technical rules of procedure are not ends in themselves but primarily devised and designed to help in the proper and expedient dispensation of justice. In appropriate cases, therefore, the rules may have to be so construed liberally as to meet and advance the cause of substantial justice. While it is desirable that the rules of procedure are faithfully and even meticulously observed, courts should not be so strict about procedural lapses that do not really impair the proper administration of justice. If the rules are intended to ensure the orderly conduct of litigation, it is because of the higher objective they seek which is the protection of substantive rights of the parties.33 Substantial justice, in other words must prevail. In Paler,34 We said:
When substantial justice dictates it, procedural rules may be relaxed in order to arrive at a just disposition of a case. The purpose behind limiting the period of appeal is to avoid unreasonable delay in the administration of justice and to put an end to controversies. A one-day delay as in this case, does not justify denial of the appeal where there is absolutely no indication of intent to delay as in this case, does not justify denial of the appeal where there is absolutely no indication of intent to delay justice on the part of Paler and the pleading is meritorious on its face.
We rule in favor of the allowance of respondents’ appeal because:
Law and jurisprudence grant to courts the prerogative to relax compliance with procedural rules of even the most mandatory character, mindful of the duty to reconcile both the need to put an end to litigation speedily and the parties’ right to an opportunity to be heard.35(Emphasis supplied)
Quoting again the case of Republic v. Court of Appeals,36we pointed out that this Court can temper rigid rules in favor of substantial justice. We find that pronouncement apt and fit to this case. Thereby we are not detained by the omissions of the respondents in their resort to the CSC, and we thus proceed to the merits of the petitioners’ submissions.
Lastly, on the form, we find no merit in the contention that Aranjuez was not authorized to sign on behalf of the other petitioners. Pursuant to Union Resolution No. 015-200837attached as Annex A to the Appellants’ 015-2008 Consolidated Memorandum dated 26 March 2008, the officers and members of NAMDACWAD gave Aranjuez a general authority to represent the organization in all legal matters to be filed for whatever purpose it may serve. From the general and broad grant of authority, Aranjuez possessed the specific authority to sign in behalf of his principal the verification and certification against non-forum shopping required of the petition."