59

GOVERNOR FELICISIMO SAN LUIS, ET AL.

vs.

COURT OF APPEALS and MARIANO BERROYA, JR.

G.R. NO. L-80160 : June 26, 1989

CORTES, J.

Facts:

Berroya, a quarry superintended in the Province of Laguna, denounced graft and corrupt practices by
employees of the said province. The petitioner then transferred Berroya to the office of the Provincial
Engineer. Berroya challenged the said transfer whereby the CSC ruled that it was violative and ordered
that Berroya be reverted to his regular position. Instead of complying with the order, the petitioner
suspended Berroya for gross discourtesy and insubordination. The CSC reiterated the immediate
reversion of Berroya and ruled the one-year suspension illegal. The petitioner then appealed to the
Office of the President which affirmed the decision of the CSC.

Issue:

Whether res judicata can be applied in the case at bar.

Held:

Yes. Since the decisions of both the Civil Service Commission and the Office of the President had long
become final and executory, the same can no longer be reviewed by the courts. It is well-established in
our jurisprudence that the decisions and orders of administrative agencies, rendered pursuant to their
quasi-judicial authority, have upon their finality, the force and binding effect of a final judgment within
the purview of the doctrine of res judicata. The rule of res judicata which forbids the reopening of a
matter once judicially determined by competent authority applies as well to the judicial and quasi-
judicial acts of public, executive or administrative officers and boards acting within their jurisdiction as
to the judgments of courts having general judicial powers.

Indeed, the principle of conclusiveness of prior adjudications is not confined in its operation to the
judgments of what are ordinarily known as courts, but it extends to all bodies upon whom judicial
powers had been conferred. Hence, whenever any board, tribunal or person is by law vested with
authority to judicially determine a question, like the Merit Systems Board of the Civil Service
Commission and the Office of the President, for instance, such determination, when it has become final,
is as conclusive between the same parties litigating for the same cause as though the adjudication had
been made by a court of general jurisdiction.
60

ARCHBISHOP FERNANDO CAPALLA, ET AL.,

vs.

THE HONORABLE COMMISSION ON ELECTIONS

G.R. NO. 201112 : October 23, 2012

PERALTA, J.

Facts:

COMELEC and Smartmatic-TIM entered into a Contract for the Provision of an Automated Election
System for the Synchronized National and Local elections (AES Contract) which is a Contract of Lease
with Option to Purchase (OTP). Several extensions were given for the OTP. COMELEC then issued a
Resolution resolving to accept Smartmatic-TIM’s offer to extend the period to exercise the OTP. The
COMELEC again issued a Resolution resolving to approve the Deed of Sale between the COMELEC and
Smartmatic-TIM to purchase the letter’s PCOS machines.

Issue:

Whether there was a grave abuse of discretion on the part of COMELEC in issuing the assailed
Resolution.

Held:

No.  A reading of the other provisions of the AES contract would show that the parties are given the
right to amend the contract which may include the period within which to exercise the option. There is,
likewise, no prohibition on the extension of the period, provided that the contract is still effective.

The deadline set in the AES Contract within which the Comelec could exercise the option. The moment
the performance security is released, the contract would have ceased to exist. However, since it is
without prejudice to the surviving provisions of the contract, the warranty provision and the period of
the option to purchase survive even after the release of the performance security. While these surviving
provisions may have different terms, in no way can we then consider the provision on the OTP separate
from the main contract of lease such that it cannot be amended under Article 19.

In this case, the contract is still effective because the performance security has not been released. Thus,
not only the option and warranty provisions survive but the entire contract as well. In light of the
contractual provisions, we, therefore, sustain the amendment of the option period.
66

MACARIO CATIPON

vs.

JEROME JAPSON

G.R. NO. 191787 : June 22, 2015

DEL CASTILLO, J.

Facts:

Respondent Japson, a former Senior Member Services Representative of SSS Bangued, filed a letter-
complaint with the CSC-CAR, alleging that petitioner made deliberate false entries in his CSPE
application, specifically, that he obtained his college degree in 1993 when actually graduated in 1995.
Also, that petitioner was not qualified to take the CSPE examination in 1993 since he was not yet then
graduate of a four-year college course, contrary to the entry in his application form.

The CSC-CAR exonerated the petitioner of the charges Dishonesty, Falsification of Official Documents
and Grave Misconduct. However, respondent is found guilty of Conduct Prejudicial to the Best Interest
of the Service. Upon appeal, the CA affirmed the CSC-CAR’S decision and held that petitioner violated
the doctrine of exhaustion of administrative remedies. Petitioner should have interposed an appeal with
the Civil Service Commission

Issue:

Whether the petitioner violated the doctrine of exhaustion of administrative remedies.

Held:

Yes. Petitioner failed to observe the principle of exhaustion of administrative remedies. As correctly
stated by the appellate court, non-exhaustion of administrative remedies renders petitioner's CA
petition premature and thus dismissible.

The doctrine of exhaustion of administrative remedies requires that "before a party is allowed to seek
the intervention of the court, he or she should have availed himself or herself of all the means of
administrative processes afforded him or her. Hence, if resort to a remedy within the administrative
machinery can still be made by giving the administrative officer concerned every opportunity to decide
on a matter that comes within his or her jurisdiction, then such remedy should be exhausted first before
the court's judicial power can be sought. The premature invocation of the intervention of the court is
fatal to one's cause of action. The doctrine of exhaustion of administrative remedies is based on
practical and legal reasons.