Cabada v. Alunan

G.R. No. 119645 (August 22, 1996)

Court ruled NAPOLCOM lacked jurisdiction; due process in admin discipline emphasized in dismissal case.

Facts:

On October 29, 1993, a complaint was filed against petitioners SPO3 Noel Cabada and SPO3 Rodolfo G. de Guzman for Grave Misconduct, Arbitrary Detention, and Dishonesty by private respondent Mario Valdez with the Office of the Commission on Human Rights in Tacloban City. The complaint was referred to the Philippine National Police Eighth Regional Command (PNP-RECOM 8), which conducted an investigation and subsequently filed administrative charges against the petitioners. On April 7, 1994, the Regional Director of PNP-RECOM 8 found the petitioners guilty of grave misconduct and ordered their dismissal from the police service, issuing Special Order No. 174 on April 23, 1994.

The petitioners contended that they were not formally provided with a copy of the decision until June 13, 1994, despite receiving the Special Order on April 26, 1994. They claimed to have filed a motion for reconsideration of the Regional Director's decision, which was not acted upon, and subsequently treated as an appeal to the Regional Appellate Board (RAB). The RAB affirmed the Regional Director's decision on August 15, 1994, and denied the petitioners' motion for reconsideration on October 25, 1994. The petitioners received the resolution on January 26, 1995.

On February 5, 1995, the petitioners filed an appeal and a petition for review with the Secretary of the Department of the Interior and Local Government (DILG) and Chairman of the National Police Commission (NAPOLCOM). However, on March 24, 1995, the NAPOLCOM denied due course to their appeal and petition for review, citing lack of jurisdiction as the decisions of the RAB had become final and executory.

Legal Issues:

  1. Did the NAPOLCOM commit grave abuse of discretion in denying due course to the petitioners' appeal and petition for review for lack of jurisdiction?
  2. Was the special civil action for certiorari prematurely filed due to the petitioners' failure to exhaust administrative remedies?

Arguments:

  • Petitioners' Arguments: The petitioners argued that the NAPOLCOM had jurisdiction over their appeal and petition for review, as the RAB's decision was not final and executory due to their timely motion for reconsideration. They contended that the NAPOLCOM's decision to deny their appeal was a grave abuse of discretion.

  • Respondents' Arguments: The Office of the Solicitor General contended that the petitioners failed to exhaust administrative remedies, asserting that they should have appealed to the Civil Service Commission (CSC) as per the Administrative Code of 1987. They argued that the NAPOLCOM's decision was correct as the RAB's decision had become final and executory.

Court's Decision and Legal Reasoning:

The Supreme Court granted the petition, annulling the NAPOLCOM's decision of March 24, 1995. The Court held that the NAPOLCOM did not have jurisdiction over the appeal and petition for review filed by the petitioners. It clarified that under Section 45 of the DILG Act of 1990, if the RAB fails to decide an appeal within the reglementary period, the decision becomes final and executory, but if the RAB does decide within that period, the decision can still be appealed to the Secretary of the DILG.

The Court emphasized that the NAPOLCOM's jurisdiction is limited to specific cases and that it cannot exercise appellate jurisdiction over its own decisions rendered through the RAB. The Court also noted that the petitioners' appeal was properly addressed to the Secretary of the DILG, and thus the NAPOLCOM's denial of due course was a nullity.

The Court further ruled that the petitioners were not required to exhaust administrative remedies since the NAPOLCOM's decision was void due to lack of jurisdiction. Therefore, the petitioners were entitled to seek certiorari directly.

Significant Legal Principles Established:

  1. The NAPOLCOM does not have appellate jurisdiction over decisions rendered by the Regional Appellate Board (RAB) in disciplinary cases involving police personnel.
  2. If a decision is rendered by the RAB within the reglementary period, it may still be appealed to the Secretary of the DILG.
  3. A decision issued by an administrative body without jurisdiction is considered a nullity, allowing for direct recourse to the courts without exhausting administrative remedies.