The Supreme Court clarified the scope of certiorari in reviewing administrative decisions. The Court emphasized that certiorari is limited to correcting jurisdictional errors, not mere errors of judgment correctable by appeal. This means that appellate courts cannot substitute their judgment for that of administrative bodies unless there is a clear showing of grave abuse of discretion, lack of jurisdiction, or excess of jurisdiction.

GSIS vs. Tesoro: Did the CA Overstep Its Certiorari Authority?

This case revolves around the administrative charges filed by the Government Service Insurance System (GSIS) against Rudy C. Tesoro, its Senior Vice-President of the Field Operations Group (SVP-FOG), regarding alleged irregularities in the award of a construction contract for the GSIS Iloilo City Field Office (GSIS-ICFO) building. The controversy began when Winston F. Garcia, then GSIS President and General Manager, reassigned Tesoro shortly after Tesoro approved the disbursement voucher for the mobilization fee of Embrocal Builders, Inc., the contractor chosen for the project. Embrocal had submitted the highest bid. Losing bidders protested, leading to an investigation revealing non-compliance with Republic Act (R.A.) No. 9184, the Government Procurement Reform Act.

Consequently, Tesoro was charged with gross neglect of duty and grave misconduct. Dissatisfied, Tesoro filed a petition for certiorari with the Court of Appeals (CA), questioning the legality of the formal charge and his preventive suspension. While the administrative proceedings continued, the GSIS found Tesoro guilty and dismissed him from service. The CA, however, modified the GSIS decision, finding Tesoro guilty only of simple neglect of duty and ordering his reinstatement with backwages. The GSIS, under Garcia, then elevated the matter to the Supreme Court, arguing that the CA had overstepped its authority in a certiorari proceeding.

The Supreme Court agreed with the GSIS, reiterating the limited scope of certiorari. The Court emphasized that certiorari is not a remedy to correct errors of judgment but only to address acts performed without or in excess of jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction. The Court cited People v. Court of Appeals, emphasizing that an appellate court acts with grave abuse of discretion when it ventures beyond its authority in certiorari proceedings to review perceived errors of the trial court correctable only by appeal by writ of error.

The appellate court acted with grave abuse of its discretion when it ventured beyond the sphere of its authority and arrogated unto itself, in the certiorari proceedings, the authority to review perceived errors of the trial court in the exercise of its judgment and discretion, which are correctible only by appeal by writ of error.

Building on this principle, the Supreme Court clarified that as long as the administrative body, in this case, the GSIS, acted within its jurisdiction, any errors committed in the exercise of its discretion would amount to mere errors of judgment, correctable by appeal, not certiorari. The proper recourse for Tesoro was to appeal the GSIS decision to the Civil Service Commission (CSC), which he initially did before withdrawing his appeal. By resolving the merits of the administrative case despite Tesoro’s pending appeal before the CSC, the CA exceeded its certiorari jurisdiction.

The Supreme Court then addressed the procedural issue of the GSIS’s delayed motion for reconsideration before the CA. While the general rule, as established in Habaluyas Enterprises, Inc. v. Japson, is that a motion for extension of time to file a motion for reconsideration does not toll the period to appeal, the Court acknowledged exceptions in the interest of substantial justice. Citing Barnes v. Padilla, the Court found that the procedural lapse was not entirely attributable to the GSIS’s fault, as the lawyer in charge had a valid reason for the delay due to a family emergency. More importantly, the Court emphasized that a careful study of the merits of the case warranted a suspension of the rules.

The Court also highlighted the importance of exhausting administrative remedies before resorting to judicial intervention. The principle of exhaustion of administrative remedies requires parties to seek relief from the administrative agencies tasked with the matter before resorting to the courts. This is because administrative agencies are presumed to have expertise in their respective fields, and allowing them to resolve the issues first promotes judicial efficiency and respect for the administrative process. However, the Court recognized exceptions to this rule, such as when purely legal questions are involved or when there is a violation of due process.

In this case, the Court found that the CA erred in not applying the principle of exhaustion of administrative remedies. Tesoro should have first appealed the GSIS decision to the CSC before seeking judicial intervention. The CA’s decision to resolve the merits of the administrative case, despite the availability of an administrative remedy, was premature and unwarranted.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals exceeded its jurisdiction in a certiorari proceeding by reviewing the merits of an administrative decision and substituting its judgment for that of the administrative body.
What is certiorari and what is its scope?	Certiorari is a special civil action used to correct acts rendered without jurisdiction, in excess of jurisdiction, or with grave abuse of discretion. It is limited to correcting jurisdictional errors, not errors of judgment that can be corrected by appeal.
What is grave abuse of discretion?	Grave abuse of discretion implies a capricious, whimsical, arbitrary, or despotic exercise of judgment that is equivalent to lack of jurisdiction. Mere abuse of discretion is not enough.
What is the principle of exhaustion of administrative remedies?	This principle requires parties to seek relief from the administrative agencies tasked with the matter before resorting to the courts. It promotes judicial efficiency and respect for the administrative process.
What are the exceptions to the exhaustion of administrative remedies?	Exceptions include cases involving purely legal questions, violations of due process, or when further administrative remedies are futile.
What was the CA’s error in this case?	The CA erred by reviewing the merits of the administrative case and finding Tesoro guilty of a lesser offense, despite the availability of an administrative remedy (appeal to the CSC).
Why was the GSIS’s motion for reconsideration considered despite being filed late?	The Supreme Court suspended the rules of procedure because the delay was due to a valid reason (family emergency) and because the merits of the case warranted a review.
What was the Supreme Court’s ruling?	The Supreme Court ruled that the CA exceeded its certiorari jurisdiction and reinstated the GSIS decision finding Tesoro guilty of gross neglect of duty and grave misconduct.

In conclusion, the Supreme Court’s decision in Garcia v. Court of Appeals and Tesoro serves as a reminder of the limits of certiorari and the importance of adhering to the principle of exhaustion of administrative remedies. This case emphasizes that courts should not interfere with administrative decisions unless there is a clear showing of jurisdictional error or grave abuse of discretion. Instead, parties should exhaust all available administrative remedies before seeking judicial intervention.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Winston F. Garcia vs. Court of Appeals and Rudy C. Tesoro, G.R. No. 169005, January 28, 2013