GSIS V. CIVIL SERVICE
FACTS
The GSIS dismissed six government employees on account of irregularities in the canvassing of supplies. The employees appealed to the Merit Board. Said board found for the employees and declared the dismissal as illegal because no hearing took place. The GSIS took the issue to the Civil Service which then ruled that the dismissal was indeed illegal. The CSC thereafter ordered the reinstatement of the employees and demanded the payment of backwages. The replacements of the dismissed employees should then be released from service.
The GSIS remained unconvinced and raised the issue to the SC. SC affirmed the Civil Service ruling saying o The CSC acted within its authority o Reinstatement was proper o However, the SC modified the requirement of backpay. Said backpay should be made after the outcome of the disciplinary proceedings.
Heirs of the dismissed employees filed a motion for execution of the Civil Service resolution so that backwages can be paid. GSIS however denied the motion saying that the SC modified that part of the ruling.
CSC nonetheless thumbed its nose to the GSIS and granted the motion. GSIS was made to pay. Backed against the wall, GSIS filed certiorari with the SC asking that the CSC order be nullified. The GSIS contends that the CSC has no power to execute its judgments.
ISSUE
Whether the Civil Service has the power to enforce its judgments
HELD
YES. The Civil Service Commission is a consitutional commission invested by the Constitution and relevant laws not only with authority to administer the civil service, but also with quasi-judicial powers. It has the authority to hear and decide administrative disciplinary cases instituted directly with it or brought to it on appeal. It has the power, too, sitting en banc, to promulgate its own rules concerning pleadings and practice before it or before any of its offices, which rules should not however diminish, increase, or modify substantive rights.
In light of all the foregoing consitutional and statutory provisions, it would appear absurd to deny to the Civil Service Commission the power or authority or order execution of its decisions, resolutions or orders. It would seem quite obvious that the authority to decide cases is inutile unless accompanied by the authority to see that what has been decided is carried out. Hence, the grant to a tribunal or agency of adjudicatory power, or the authority to hear and adjudge cases, should normally and logically be deemed to include the grant of authority to enforce or execute the judgments it thus renders, unless the law otherwise provides.
Therefore, the GSIS must yield to the order of the CSC.
