G.R. No. 82304 November 29, 1989
HONORATO M. FRUTO, petitioner, vs. HONORABLE RAINERO O. REYES, Secretary, Department of Transportation and Communications, and LINA L. ESTRADA, Regional Director, National Capital Region, Land Transportation Office, respondents.

FACTS

The petitioner, Honorato M. Fruto, was a long-time employee of the Land Transportation Commission (LTC) and its successor agency, the Bureau of Land Transportation (BLT). He held various positions, culminating in his appointment as Registrar. In 1979, he was relieved from this post and given successive reassignments, which he contended effectively constituted illegal separation from service. Consequently, Fruto filed a complaint with the Merit Systems Board.
On July 8, 1981, the Merit Systems Board rendered a decision in favor of Fruto. The Board found his reassignment unjustified and not in the interest of the service, noting he was not issued a new appointment following the reorganization. It directed that Fruto be appointed to the same or a similar position he previously occupied. The BLT received a copy of this decision on July 8, 1981. However, the BLT filed a motion for reconsideration only on July 29, 1981, which was 21 days after receipt, thereby beyond the reglementary 15-day period. Despite this tardiness, the Board entertained the motion and eventually reversed its original decision, dismissing Fruto’s complaint.

ISSUE

The core issue is whether the Merit Systems Board’s July 8, 1981 decision had attained finality, thereby rendering its subsequent reversal null and void.

RULING

The Supreme Court ruled in favor of the petitioner, Fruto. The Court held that the Merit Systems Board’s initial decision of July 8, 1981, ordering his reinstatement, had become final and executory. This finality was triggered by the BLT’s failure to file a timely motion for reconsideration within the 15-day period prescribed by Section 39 of Presidential Decree No. 807 (The Civil Service Decree). Since the motion for reconsideration was filed six days late, the Board lost jurisdiction to alter its original decision.
The legal logic is grounded on the doctrine of finality of judgments and the mandatory nature of procedural periods. The Court emphasized that rules of procedure, while based on equity, are imbued with the character of law to ensure the orderly administration of justice and the termination of litigation. The Board’s act of entertaining the belated motion and subsequently reversing itself based on evidence it had already scrutinized and rejected in its first decision constituted an invalid “flip-flopping.” The Court found no equitable grounds to justify the relaxation of the procedural rule in this instance, distinguishing it from cases where such relaxation was warranted. Consequently, the reversed “decision” of May 17, 1985, was declared null and void. The Court ordered Fruto’s reinstatement to his former or an equivalent position and awarded him three years of backwages without deduction.