### Facts:
This case arose from the termination of Marie Jean C. Lapid (‘Lapid’), a Casual Clerk (Teller) at the Philippine Charity Sweepstakes Office (PCSO) in Bataan, due to allegations of Discourtesy in the Course of Official Duties and Grave Misconduct based on an incident on June 17, 2005. Following a sworn statement by Mr. Lolito O. Guemo documenting the alleged misconduct, the PCSO Legal Department, through Atty. Victor M. Manlapaz, eventually recommended the issuance of Formal Charges. Despite the recommended issuance of Formal Charges, it was observed that Lapid was never formally charged nor was proper due process observed in the termination of her services. Lapid’s appeal to the Civil Service Commission (CSC) was dismissed on grounds that her casual employment status rendered the appeal moot and academic, citing her lack of security of tenure. Dissatisfied, Lapid petitioned the Court of Appeals (CA), challenging the CSC’s decision and emphasizing a lack of due process in her termination.
### Issues:
1. Whether casual employees enjoy security of tenure and the protection against arbitrary dismissal without due process.
2. Whether the termination of Marie Jean C. Lapid from the PCSO violated her right to due process.
### Court’s Decision:
The Supreme Court denied the petition filed by the PCSO Board of Directors and Reynaldo P. Martin, affirming the CA’s ruling that Lapid’s dismissal violated her due process rights. The Court clarified that even casual or temporary employees are entitled to security of tenure under the Constitution and relevant civil service laws – meaning they cannot be dismissed except for cause and following due process.
The Court found that Lapid was not duly informed of the formal charges against her nor was a formal investigation conducted, which constituted a violation of her right to due process. Thus, the Supreme Court ordered her reinstatement and entitlement to backwages from the date of dismissal until actual reinstatement or the end of her employment term, whichever came first.
### Doctrine:
The Supreme Court elucidated the principle that all government employees, including casual and temporary workers, are entitled to security of tenure under the Constitution and Civil Service Laws. They cannot be arbitrarily dismissed without just cause and proper observance of due process.
### Class Notes:
– **Security of Tenure for Government Employees**: The Constitution and Civil Service laws protect all government employees, including casual and temporary workers, from arbitrary dismissal. They can only be terminated for valid reasons as stipulated by law, after due process is observed.
– **Due Process**: Involves the proper notification of charges against an employee and the conduct of a formal investigation allowing the employee a fair chance to answer the allegations and defend themselves.
– **Casual Employment**: Refers to positions filled due to exigency of the service where there are not enough regular staff, with the understanding that such employment could cease at the end of the period unless renewed. However, termination prior must be for cause and follow due process.
### Historical Background:
This case underscores the evolving interpretation of casual and temporary employees’ rights within the Philippine government sector. It builds on previous jurisprudence, asserting that even non-regular employees have basic rights that the state and its agencies must respect, marking a significant stance on protecting employees from unjust employment practices.
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