Ampong v Civil Service Commission

FACTS
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A Professional Board Examination for Teachers (PBET) was held in Davao City
Evelyn Junio-Decir took the exam and passed with a rating of 74.27%
A woman representing herself as Evelyn Decir went to the Civil Service Regional Office to
claim a copy of her PBET Certificate of Eligibility
CSRO personnel noticed that the picture of the examinee didnt match the appearance of
the woman claiming the certificate of eligibility
It turns out that it was petitioner Ampong who took and passed the examinations under
Evelyn Decirs name
o Ampong at the time of the examination was a public school teacher and was also,
at the same time, a Court Interpreter III of the RTC in Alabel, Sarangani Province
The CSRO conducted an investigation and a case against Decir and Ampong for
dishonesty, grave misconduct and conduct prejudicial to the best interest of the service
Decir reasoned out that the proctor might have made a mistake in pasting the wrong
picture on her information sheet and that her signature was different because it was her
signature when she was still unwed
Ampong voluntarily appeared at the CSRO and admitted to the wrong doing
Decir and Ampong were both found guilty
Petitioner, however, moved for reconsideration and raised the issue of jurisdiction
o She argued that the exclusive authority to discipline employees of the
judiciary lies with the Supreme Court
o According to the CSC, administrative supervision is distinct from administrative
jurisdiction

while it is true that this Commission does not have administrative

supervision over employees in the judiciary, it has concurrent jurisdiction
over them, as provided by the Administrative Code of 1987

CSC shall have the power to hear and decide administrative cases
instituted by or through it directly or on appeal, including
contested appointment, and review decisions and actions of its
offices and of the agencies attached to it

ISSUE
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W/N the CSC has administrative jurisdiction over an employee of the Judiciary for acts
committed while said employee was still with the Executive or Education Department

NO

While the CSC has administrative jurisdiction over the civil service, the Constitution
provides that the Supreme Court is given exclusive administrative jurisdiction over all
courts and judicial personnel
o It is only the SC that can oversee the judges and court personnels compliance
with all laws, rules, and regulations.
Also, administrative jurisdiction over petitioner belongs to the SC because the action has
been instituted by the CSC at the time when petitioner was already a judicial employee
HOWEVER, the Court is constrained to uphold the ruling of the CSC based on the principle
of estoppel because petitioner has affirmed and invoked the jurisdiction of a court or
tribunal and, therefore, may not afterwards deny that same jurisdiction to escape penalty

HELD
RATIO