GR 96938; (October, 1991) (Digest)
G.R. No. 96938 October 15, 1991
GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS), petitioner, vs. CIVIL SERVICE COMMISSION, HEIRS OF ELIZAR NAMUCO, and HEIRS OF EUSEBIO MANUEL, respondents.
FACTS
In 1981, the GSIS dismissed six employees for being “notoriously undesirable.” The Civil Service Commission (CSC) later declared the dismissals illegal due to lack of formal charge and hearing, ordering their reinstatement with back wages. The GSIS appealed to the Supreme Court. In a 1988 Resolution, the Court affirmed the illegality of the dismissal and ordered reinstatement but eliminated the payment of back salaries pending new disciplinary proceedings. The Court also noted that two employees, Elizar Namuco and Eusebio Manuel, had already passed away.
Following the finality of the Supreme Court’s Resolution, the heirs of Namuco and Manuel moved for execution before the CSC to claim back salaries from the date of illegal dismissal until the date of death. The GSIS opposed, arguing the Supreme Court’s Resolution had superseded the CSC’s earlier order for back wages. The CSC granted the heirs’ motion, directing the GSIS to pay. The GSIS filed a motion for reconsideration, which was denied.
ISSUE
The core issues are: (1) whether the Civil Service Commission has the power to execute its final orders and resolutions; and (2) whether the CSC’s execution order, granting back salaries to the heirs, varied or contradicted the Supreme Court’s 1988 Resolution.
RULING
The Supreme Court ruled in favor of the CSC’s authority and the propriety of the execution. On the first issue, the Court held that the CSC, as a constitutional body with quasi-judicial powers, inherently possesses the authority to execute its final decisions. This power is essential to make its adjudicatory function effective and is supported by its own procedural rules and relevant statutes, which provide for the immediate executory nature of its decisions unless restrained by the Supreme Court.
On the second issue, the Court found no contradiction. The Supreme Court’s 1988 Resolution eliminated back salaries for the living employees only as to the period after its issuance, pending new proceedings. It did not nullify the employees’ entitlement to back salaries for the period of illegal dismissal prior to their deaths. The right to back wages accrues from the illegal separation and survives the employee’s death, inuring to the benefit of their heirs. Therefore, the CSC’s order for the GSIS to pay back salaries from the date of illegal dismissal up to the date of death was a proper execution of the final and executory judgment declaring the dismissal illegal, and it did not alter the Supreme Court’s directive. The petition was dismissed.