Buenaflor v Ramirez G.R. No.

201607, [February 15, 2017]

Petitioner: Hon. Cesar Buenaflor
Respondent: Jose R. Ramirez, Jr.
Ponente: Justice Bersamin

FACTS
Eufemio Domingo, Chairman of the Presidential Anti-Graft Commission (PAGC), appointed Jose Ramirez Jr. as Executive
Assistant III and designated him as Assistant Accountant. When Chairman Domingo resigned, Hon. Cesar Buenaflor
succeeded him. Buenaflor fired Ramirez on the ground that his tenure had expired since his position as Executive
Assistant is personal and confidential and is co-terminus with that of the appointing authority.

Ramirez believed that his appointment was contractual in nature so he sued Buenaflor in the RTC for unlawful
termination and prayed to declare his dismissal as null and void.

Buenaflor contended that Ramirez failed to exhaust administrative remedies and should have filed an administrative
complaint in the CSC.

The RTC ruled that Buenaflor was guilty of the crime charged. Buenaflor failed to prove that Ramirez’s employment was
co-terminus with that of chairman Domingo. Buenaflor filed a MR but it was denied because of being filed out of time.

Buenaflor filed before the CA a petition for certiorari alleging that the RTC gravely abused its discretion amounting to
lack or excess of jurisdiction. However, the CA dismissed the petition. He moved for a reconsideration but it was denied..

ISSUE
WON the Court of Appeals committed grave abuse of discretion in not declaring that the RTC has no jurisdiction to hear
and decide the instant civil service related case, which is under the sole jurisdiction of the CSC.

RULING
Yes, the CA committed grave abuse of discretion in not declaring that the RTC has no jurisdiction to hear and decided the
civil service related case.

Section 2 (1) of Article IX-B of the Constitution vests in the CSC the jurisdiction over all employees of the Government,
including all its branches, subdivisions, instrumentalities, and agencies, as well as government-owned or controlled
corporations with original charters. Disciplinary cases and cases involving personnel actions affecting employees in the
Civil Service, like appointment or separation from the service, are within the exclusive jurisdiction of the CSC.
In this case, Ramirez was an employee of the PAGC, an office established by President Macapagal-Arroyo through
Executive Order No. 12 as an agency under the Office of the President and is thus under the CSC. Buenaflor was entirely
justified in raising in his answer the special and affirmative defense that the RTC was bereft of jurisdiction to hear and
resolve Ramirez's complaint. The CA should have heard and granted the petition for certiorari of Buenaflor instead of
dismissing it .

NOTES
★ CA dismissed the petition on technical grounds: (1) the petition does not state the date of issue of Buenaflor’s
MCLE Certificate of Compliance as required; (2) Buenaflor’s counsel’s PTR number is not current; and (3) the actual
address of the parties are not stated.
★ CSC has jurisdiction over a case involving a civil servant if it can be regarded as equivalent to a labor dispute
resoluble under the Labor Code.
★ Regular court has jurisdiction if the case can be decided under the general laws, such as when the case is for the
recovery of private debts, or for the recovery of damages due to slanderous remarks of the employer, or tor
malicious prosecution of the employees.
★ When a court has no jurisdiction over the subject matter, the only power it has is to dismiss the action. Upon the
filing of the complaint, the RTC could only have dismissed it for lack of jurisdiction. Any further actions the RTC
took, including rendering the decision, were void and ineffectual. Verily, the decisions or orders rendered by courts
without or in excess of their jurisdiction are void, and cannot be the source of any right, or the creator of any
obligation.