Remedial Law- Appeal

CIVIL SERVICE COMMISSION V. MADLAWI B. MAGOYAG

GR. No. 197792, December 9, 2015

FACTS: Madlawi Magoyag, a government employee, filed with the RTC of Lanao Del Sur
a Petition for Correction of his date of birth from July 22, 1947 to July 22, 1954; the latter being
the date appearing in his Certificate of Live Birth. The wrong date appeared in the records of the
GSIS and was maintained in the entire length of his stay in the government. After considering all
the supporting evidence submitted by Madlawi, the RTC granted his petition and directed the
Local Civil Registrar and Civil Service Commission to effect the correction in their respective
records. Madlawi requested the CSC to correct his date of birth appearing in his employment
records as directed by the RTC in its decision but the CSC denied the request on the ground that
the decision of the RTC was not yet final and executory. Madlawi filed a Motion for
Reconsideration attaching thereto the Certificate of Finality issued by the RTC but the same was
denied by the CSC. Aggrieved, Madlawi filed a Petition for Review under Rule 43 of the Rules
of Court to the Court of Appeals. The CA granted the petition and ordered the CSC to comply
with the decision of the RTC. CSC filed a motion for reconsideration with the CA but was
denied. CSC elevated the case to the Supreme Court arguing that the resolutions it issued
denying the request of Madlawi are mere responses to the said request and although discretion
was exercised in such denial, it cannot be said to be judicial in nature because there were no
investigations or hearings held to determine or ascertain the facts. Thus, the issuance of those
resolutions was not the result of its quasi-judicial functions but of its administrative function. As
such, Madlawi erred in resorting to Rule 43 when he elevated the case to the CA because only
those judgments, final orders or resolutions issued in the exercise of its quasi-judicial functions
may be the subject of a Petition for Review under Rule 43 of the Rules of Court.

ISSUE: Whether or not Petition for Review under Rule 43 is proper under the facts?

RULING: The SC ruled that the resolutions issued by the petitioner are not merely responses
but actually quasi-judicial actions because the result of those resolutions is the denial of a right
conferred by the RTC to the respondent. When the petitioner denied the request of the respondent
in the exercised of its discretion, it did not merely perform an administrative function but had
already adjudicated on the matted. Therefore, resort to Rule 43 of the Rules of Court was proper.