CASE DIGEST
SAN FELIX v. CIVIL
SERVICE COMMISSION
G.R. No. 198404,
October 14, 2019
THIRD DIVISION, HERNANDO
J.
Powers, Function and
Jurisdiction of Civil Service Commission
DOCTRINE: CSC's role as the central personnel
agency responsible for upholding the integrity of the civil service system and
maintaining the merit and rewards system. The case establishes that the CSC's
jurisdiction extends to matters of integrity, honesty, and misconduct within
the civil service, regardless of changes in specific examination administration
authority.
San Felix was accused of allowing
another person to take a police officer exam in his place, leading to the CSC's
imposition of penalties. The CSC found San Felix guilty of dishonesty for
allegedly allowing someone else to take a police officer examination on his
behalf and imposed the penalty of dismissal from service along with other
related penalties. San Felix contested this, claiming that the CSC lacked
jurisdiction to conduct investigations and render administrative decisions due
to a law transferring examination authority to the National Police Commission
(NPC). The petition concerns the legal challenge against the Court of Appeals'
decision to uphold the Civil Service Commission's (CSC) findings against Melvin
G. San Felix.
Whether the Civil Service Commission (CSC) retains
jurisdiction to conduct investigations and render administrative decisions
based on alleged anomalies in police entrance and promotional examinations
after the creation of the National Police Commission (NPC).
YES. The Civil Service Commission (CSC) retains
authority and jurisdiction to investigate anomalies and irregularities in civil
service examinations and impose appropriate sanctions. The court found that the
CSC has the power to administer the merit system and carry out measures to
ensure the integrity of the civil service, including investigations related to
examination fraud. Although a law transferred examination authority for police
officers to the National Police Commission (NPC), the CSC's jurisdiction
remained for investigations involving integrity and falsification of
information in personal data sheets. The court held that the petitioner's act
of dishonesty by allowing someone else to take an examination for him and
making false statements on his personal data sheet warranted disciplinary action,
as it was in violation of the merit and rewards system. Therefore, the court
upheld the CSC's jurisdiction and its decision to impose sanctions on the
petitioner.
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