Subject: Administrative Law

Topic: Power to Enforce its Decision

Title: GSIS V. CIVIL SERVICE

Citation: G.R. No. 96938, October 15, 1991

FACTS:

The GSIS dismissed six government employees on account of

irregularities in the canvassing of supplies. The employees appealed to
the Merit Board. Said board found for the employees and declared the
dismissal as illegal because no hearing took place. The GSIS took the
issue to the Civil Service which then ruled that the dismissal was indeed
illegal. The CSC thereafter ordered the reinstatement of the employees
and demanded the payment of backwages. The replacements of the
dismissed employees should then be released from service.

The GSIS remained unconvinced and raised the issue to the SC. SC
affirmed the Civil Service ruling saying o The CSC acted within its
authority o Reinstatement was proper o However, the SC modified the
requirement of backpay. Said backpay should be made after the
outcome of the disciplinary proceedings.

Heirs of the dismissed employees filed a motion for execution of the

Civil Service resolution so that backwages can be paid. GSIS however
denied the motion saying that the SC modified that part of the
ruling.
CSC nonetheless thumbed its nose to the GSIS and granted the
motion. GSIS was made to pay. Backed against the wall, GSIS filed
certiorari with the SC asking that the CSC order be nullified. The GSIS
contends that the CSC has no power to execute its judgments.

Issue:

Whether the Civil Service has the power to enforce its judgments

Ruling:

YES. The Civil Service Commission is a consitutional commission

invested by the Constitution and relevant laws not only with authority
to administer the civil service, but also with quasi-judicial powers. It has
the authority to hear and decide administrative disciplinary cases
instituted directly with it or brought to it on appeal. It has the power,
too, sitting en banc, to promulgate its own rules concerning pleadings
and practice before it or before any of its offices, which rules should not
however diminish, increase, or modify substantive rights.


In light of all the foregoing consitutional and statutory provisions, it

would appear absurd to deny to the Civil Service Commission the power
or authority or order execution of its decisions, resolutions or orders. It
would seem quite obvious that the authority to decide cases is inutile
unless accompanied by the authority to see that what has been decided
is carried out. Hence, the grant to a tribunal or agency of adjudicatory
power, or the authority to hear and adjudge cases, should normally and
logically be deemed to include the grant of authority to enforce or
execute the judgments it thus renders, unless the law otherwise
provides.