The Civil Service Commission denied Madlawi Magoyag's request to correct his date of birth in government employment records from 1947 to 1954 based on a court order. Magoyag appealed this decision. The Court ruled that the Commission exercised quasi-judicial functions in denying the request, as it required investigating facts and exercising discretion. Even though no hearings were held, the Commission's decision adjudicated Magoyag's legal rights. Therefore, the appeal was properly filed according to Rule 43, and the Commission must comply with the court order to correct Magoyag's date of birth.
The Civil Service Commission denied Madlawi Magoyag's request to correct his date of birth in government employment records from 1947 to 1954 based on a court order. Magoyag appealed this decision. The Court ruled that the Commission exercised quasi-judicial functions in denying the request, as it required investigating facts and exercising discretion. Even though no hearings were held, the Commission's decision adjudicated Magoyag's legal rights. Therefore, the appeal was properly filed according to Rule 43, and the Commission must comply with the court order to correct Magoyag's date of birth.
The Civil Service Commission denied Madlawi Magoyag's request to correct his date of birth in government employment records from 1947 to 1954 based on a court order. Magoyag appealed this decision. The Court ruled that the Commission exercised quasi-judicial functions in denying the request, as it required investigating facts and exercising discretion. Even though no hearings were held, the Commission's decision adjudicated Magoyag's legal rights. Therefore, the appeal was properly filed according to Rule 43, and the Commission must comply with the court order to correct Magoyag's date of birth.
The Civil Service Commission denied Madlawi Magoyag's request to correct his date of birth in government employment records from 1947 to 1954 based on a court order. Magoyag appealed this decision. The Court ruled that the Commission exercised quasi-judicial functions in denying the request, as it required investigating facts and exercising discretion. Even though no hearings were held, the Commission's decision adjudicated Magoyag's legal rights. Therefore, the appeal was properly filed according to Rule 43, and the Commission must comply with the court order to correct Magoyag's date of birth.
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CIVIL SERVICE COMMISSION v. records from July 22, 1947 to July 22, 1954.
MAGOYAG (2015) The said request was then forwarded to the
CSC-National Capital Region (NCR) and, TOPIC Administrative agencies – thereafter, the request was endorsed to the Judicial Function CSC. DOCTRINE Quasi-judicial function is a term which applies to the In support of his request, respondent action, discretion, etc. of submitted copies of his certificate of live public administrative birth issued by the National Statistics Office officers or bodies, who are required to investigate facts (NSO), together with the November 20, or ascertain the existence 2007 Decision of the RTC in the case of facts, hold hearings, and entitled, "In the Matter of the Correction of draw conclusions from Date of Birth Madlawi B. Magoyag. them as a basis for their official action and to Respondent claims that the discrepancy in exercise discretion of a his date of birth arose when he applied for judicial nature. employment with Amanah Bank in 1974 when he mistakenly placed 1947 instead of It is true that only those 1954 as his year of birth in the application awards, judgments, final orders or resolutions of a form. Thus, according to him, such wrong quasi-judicial agency or date appeared in the records of the GSIS body in the exercise of its and was maintained in the entire length of quasi-judicial functions are his stay in the government. the subjects of an appeal under Rule 43 of the Rules Petitioner CSC denied respondent's request of Court. However, in the on the ground that the RTC decision present case, petitioner rendered on November 20, 2007 was not maintains that the yet final and executory. resolutions it issued were mere responses to the respondent's request for Respondent filed a motion for the correction of his date of reconsideration and attached to it was the birth. However, petitioner Certificate of Finality of Judgment issued by admits that in issuing those the RTC. On March 16, 2010, the CSC, in resolutions, it exercised its its Resolution No. 100491, denied the said discretion. motion,
PERALTA, J. Aggrieved, respondent filed a Petition for
Review under Rule 43 of the Rules of I.FACTS Court with the CA and the latter granted the petition and ordered the CSC to comply with Respondent filed with the RTC of Lanao del the Decision of the RTC. Sur a petition for correction of his date of birth from July 22, 1947 to July 22, 1954. The CSC arguments: On November 20, 2007, the RTC granted the said petition. Petitioner argues that the resolutions it issued regarding the request of the On February 6, 2008, respondent, who was respondent for the correction of his date of then the Deputy Collector of the Bureau of birth are mere responses to the said Customs in Cagayan de Oro City requested request and that although discretion was the CSC Regional Office to correct his date exercised by petitioner in denying the of birth appearing in his employment request, said exercise of discretion cannot be said to be judicial in nature officers or bodies, who are required to because there were no investigations or investigate facts or ascertain the hearings held to determine or ascertain the existence of facts, hold hearings, and facts. Thus, according to the petitioner, the draw conclusions from them as a basis for their official action and to exercise issuance of those resolutions was not discretion of a judicial nature. the result of its quasi-judicial function, but of its administrative function only. As It is true that only those awards, judgments, such, petitioner insists, respondent erred in final orders or resolutions of a quasi-judicial resorting to Rule 43 of the Rules of Court agency or body in the exercise of its quasi- when he elevated the case to the CA. judicial functions are the subjects of an Petitioner further reiterates that only those appeal under Rule 43 of the Rules of Court. judgments, final orders or resolutions issued However, in the present case, petitioner in the exercise of its quasi-judicial functions maintains that the resolutions it issued were may be the subject of a petition for review mere responses to the respondent's request under Rule 43. for the correction of his date of birth. However, petitioner admits that in issuing those resolutions, it exercised its discretion: II.ISSUE “..While discretion was exercised by WON the resolution issued by the CSC are petitioner in denying such request by reviewable under Rule 43 of the Rules of respondent, said exercise of discretion Court - YES cannot be said to be of judicial nature. In acting on the request, no investigations or hearings were held to ascertain or III.RATIO determine the facts..”
CSC petition is denied. What makes it more unfortunate is that
petitioner even admits on not having any This Court rules that the resolutions investigations or hearings before issuing issued by petitioner are not mere such resolutions. The first resolution responses to a request but are actually denying the request was understandable quasi-judicial actions because the result since petitioner was not able to submit a of those resolutions is the denial of a certificate or proof of the finality of the right of the respondent as conferred by RTC's judgment, but the second resolution the court. denying the motion for reconsideration was unforgivable since the respondent was Rule 43 of the Rules of Court under which already able to cure the defect of its first respondent filed his petition before the CA request by attaching the Certificate of applies to awards, judgments, final orders or Finality of Judgment issued by the RTC. resolutions of or authorized by any quasi- Thus, by denying respondent's request, judicial agency in the exercise of its quasi- petitioner was not merely exercising an judicial functions: administrative function but had already adjudicated on the matter. Therefore, the An agency is said to be exercising resort to Rule 43 was proper. judicial function where [it] has the power to determine what the law is and what In denying respondent's request, petitioner the legal rights of the parties are, and emphasized that it did not give weight to the then undertakes to determine these certified photocopies of respondent's school questions and adjudicate upon the rights records which he submitted to support his of the parties. Quasi-judicial function is a request because according to the Official term which applies to the action, discretion, etc. of public administrative Transcript of Records issued by the Office of the University Registrar of Liceo de Cagayan University, respondent graduated from college in November 1967 which is manifestly improbable if respondent's claim that he was born on July 22, 1954 is true because it would mean that he graduated from college at the age of thirteen (13), from high school at nine (9), and from elementary at five (5). Such assumption should have merited an investigation and hearing if petitioner deemed such scenario as improbable because there are cases where such an instance is possible.
It must be remembered that, a petition for
correction is an action in rem, an action against a thing and not against a person. It is the publication of such notice that brings in the whole world as a party in the case and vests the court with jurisdiction to hear and decide it. As such, petitioner is now legally bound to acknowledge and give effect to the judgment of the RTC.
However, petitioner totally disregarded the
finality of the RTC's judgment. This doctrine of finality of judgment is grounded on fundamental considerations of public policy and sound practice. In fact, nothing is more settled in law than that once a judgment attains finality it thereby becomes immutable and unalterable.
Gios-Samar, Inc., Represented by Its Chairperson Gerardo M. Malinao, Petitioner, vs. Department of Transportation and Communications and Civil Aviation Authority of The Philippines, Respondents.