G.R. No. 153188 ; August 14, 2007
JERRYBELLE L. BUNSAY, et al., Petitioners, vs. CIVIL SERVICE COMMISSION and CITY OF BACOLOD, Respondents.

FACTS

Petitioners were among 59 employees of Bacolod City whose promotional appointments were initially disapproved by the Civil Service Commission (CSC) Field and Regional Offices. On appeal, the CSC upheld the validity of their appointments in separate 2001 resolutions. However, these resolutions did not provide for the payment of backwages. Consequently, 22 of the appointees, including petitioners, filed a request for back pay with the CSC.
The CSC denied their request in Resolution No. 01-0872. Upon motion for reconsideration, the CSC partially granted relief in Resolution No. 02-0016. It awarded backwages to some employees but denied the claims of the 17 petitioners herein, either wholly or partly, primarily on the ground of insufficient evidence, such as lack of Daily Time Records (DTRs) to prove they rendered service during the period their appointments were pending approval.

ISSUE

Whether the Court of Appeals erred in dismissing petitioners’ appeal on purely technical grounds, thereby precluding a review on the merits of their entitlement to backwages.

RULING

Yes. The Supreme Court reversed the Court of Appeals’ dismissal and remanded the case for resolution on the merits. The Court emphasized the policy of deciding cases based on substantive rights rather than procedural technicalities. Petitioners’ procedural lapses in their CA petition, specifically the initial failure to attach certain documents and to explain non-personal service, were cured when they submitted the required documents and offered a plausible explanation in their motion for reconsideration. This constituted substantial compliance warranting the relaxation of procedural rules.
More importantly, the core issue of entitlement to backwages for appointees whose promotions were ultimately approved by the CSC is a significant legal matter that deserves adjudication on the merits. The Court found it prudent to excuse the technical lapse to afford petitioners a full review, especially since they had already prevailed on the main issue of the validity of their appointments. Denying them a hearing on the ancillary claim for backwages on a technicality would be unjust. The case was thus remanded to the Court of Appeals to resolve the substantive issue of whether petitioners are entitled to backwages for the period between the issuance of their promotional appointments and the CSC’s final approval, and to receive and evaluate the evidence on this matter.