Case Digest: MENELIETO A. OLANDA v. LEONARDO G. BUGAYONG et al. 413 SCRA 255 (2003)

MENELIETO A. OLANDA v. LEONARDO G. BUGAYONG et al. 413 SCRA 255 (2003)

Twelve officers and employees of the Philippine Merchant Marine Academy (PMMA) including petitioner Manelieto A. Olanda (Olanda), then Dean of the College of Marine Engineering and former PMMA Complex Project Officer, filed a verified complaint with the Office of the Ombudsman against respondent Leonardo G. Bugayong (Bugayong), President of the PMMA, charging him with violation of Section 3 (g) of Republic Act No. 3019, as amended, otherwise known as the Anti-Graft and Corrupt Practices Act, for entering into a grossly disadvantageous contract with the Philippine National Construction Corporation (PNCC) on behalf of PMMA. Respondent Pedro S. Dulay, Jr. (Dulay), chief security officer of the PMMA, by a letter addressed to Bugayong, stated that he heard the radio interview of Olanda and that in discussing publicly without any clearance from Bugayong the Memorandum of Agreement between PMMA and PNCC, Olanda violated the PMMA Faculty Handbook and other civil service rules. Bugayong relieved Olanda as the dean of the PMMA by a special order and designated him as an acting executive assistant in the Graduate School Program at the Pamantasan ng Lungsod ng Makati (PLM). Bugayong, by decision, suspended petitioner for three months for violation of the PMMA Faculty Handbook and the civil service rules. Olanda filed a petition with the Regional Trial Court (RTC) of Iba, Zambales for quo warranto, mandamus and prohibition with prayer for the issuance of writ of preliminary injunction and damages, claiming that there was no valid cause to deprive him of his position as Dean and that Bugayong was usurping his position. However, the RTC dismissed the case for lack of cause of action and that Olanda has not exhausted all administrative remedies. 

ISSUE:

Whether or not the dismissal of the case against Bugayong is proper.

HELD:

As a rule, the Court reviews only the specific issues or errors raised by the parties. However, even if not raised, an error in jurisdiction may be taken up. Disciplinary cases and cases involving personal actions‘ affecting employees in the civil service including appointment through certification, promotion, transfer, reinstatement, reemployment, detail, reassignment, demotion and separation are within the exclusive jurisdiction of the Civil Service Commission which is the sole arbiter of controversies relating to the civil services. It was thus error for the trial court, which does not have jurisdiction, to, in the first place, take cognizance of the petition of Menelieto Olanda assailing relief as Dean and his designation to another position. This leaves it unnecessary to dwell on the issues herein raised by Olanda.