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GSIS Vs CSC Case Digest

The GSIS dismissed six government employees without a hearing due to irregularities in supplying contracts. The Merit Board and Civil Service Commission found the dismissals illegal and ordered reinstatement and backpay. The SC affirmed except modified that backpay would be determined after disciplinary proceedings. Heirs of two deceased employees filed for execution of backpay. While the GSIS denied the motion citing the SC modification, the CSC granted the motion. The GSIS challenged the CSC's authority to enforce its judgments. The SC ruled that the CSC has constitutional and statutory power as a quasi-judicial body to not only adjudicate cases but also enforce its decisions, as denying enforcement power would render its adjudicatory power meaningless.

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701 views

GSIS Vs CSC Case Digest

The GSIS dismissed six government employees without a hearing due to irregularities in supplying contracts. The Merit Board and Civil Service Commission found the dismissals illegal and ordered reinstatement and backpay. The SC affirmed except modified that backpay would be determined after disciplinary proceedings. Heirs of two deceased employees filed for execution of backpay. While the GSIS denied the motion citing the SC modification, the CSC granted the motion. The GSIS challenged the CSC's authority to enforce its judgments. The SC ruled that the CSC has constitutional and statutory power as a quasi-judicial body to not only adjudicate cases but also enforce its decisions, as denying enforcement power would render its adjudicatory power meaningless.

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Ebbe Dy
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Title : GOVERNMENT SERVICE INSURANCE SYSTEM vs.

CIVIL SERVICE COMMISSION,


HEIRS OF ELIZAR NAMUCO, and HEIRS OF EUSEBIO MANUEL
Citation : G.R. No. 96938
October 15, 1991
Ponente : NARVASA, J.

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 constitutional 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 constitutional 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.

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