**Facts:**
1. **1987 Reorganization:** The reorganization of the Ministry of Health commenced under Executive Order No. 119, resulting in various personnel transfers and office abolitions.
2. **Dr. de la Fuente’s Position:** Dr. Alejandro de la Fuente, Chief of Clinics at the National Children’s Hospital (NCH), viewed his appointment to Medical Specialist II as a significant demotion.
3. **Protest:** De la Fuente filed a protest with the DOH Reorganization Board and subsequently with the Civil Service Commission (CSC), which decided in his favor, directing his reinstatement and payment of back salaries.
4. **CSC Resolution:** The CSC’s resolution became final on September 21, 1988, with no appeal or reconsideration filed.
5. **Non-Compliance by Vital-Gozon:** Despite two demands from de la Fuente, Medical Center Chief Dr. Isabelita Vital-Gozon referred the issue to the DOH Legal Affairs and failed to comply with the CSC order.
6. **Mandamus Action:** De la Fuente filed a mandamus and damages action with the Court of Appeals (CA) on December 28, 1988, seeking enforcement of the CSC resolution and claiming damages.
7. **CA’s Initial Ruling (1989):** The CA ordered compliance with the CSC resolution but denied damages, stating mandamus was not the appropriate mechanism for such claims.
8. **Motion for Reconsideration:** De la Fuente’s motion argued the CA had jurisdiction over damages under BP 129, which the CA eventually upheld, reopening proceedings for the damages claim.
9. **Proceedings and Delays:** Multiple procedural delays, including non-filing of answers and a series of hearings, ensued. Vital-Gozon eventually challenged CA’s jurisdiction over damages but was unsuccessful.
10. **Final CA Ruling (1997):** The CA awarded de la Fuente moral and exemplary damages and attorney’s fees, leading Vital-Gozon to seek redress in the Supreme Court.
**Issues:**
1. **Jurisdiction:** Whether the Court of Appeals had jurisdiction to award damages in a mandamus case.
2. **Due Process:** Whether Dr. Isabelita Vital-Gozon was denied due process when the appellate court refused to admit her belated answer.
3. **Merit of Awards:** The propriety of the awards for moral damages, exemplary damages, and attorney’s fees.
**Court’s Decision:**
1. **Issue of Jurisdiction:**
– The Supreme Court confirmed that under BP 129, the CA had concurrent jurisdiction with the Supreme Court and RTC to issue writs of mandamus and could award damages as part of this jurisdiction.
2. **Due Process:**
– The Court held that Vital-Gozon wasn’t denied due process. The CA’s repeated orders for her to file an answer, her non-compliance, and numerous procedural opportunities rebutted claims of due process violation.
3. **Merit of Awards:**
– **Moral Damages:** Affirmed. The CA found sufficient factual basis for de la Fuente’s claim of emotional distress due to the undue delay and willful non-compliance with the CSC resolution.
– **Exemplary Damages:** Affirmed. The CA appropriately awarded exemplary damages to set a precedent for public official accountability.
– **Attorney’s Fees:** Affirmed. The award was justified based on the bad faith and dilatory tactics employed by Vital-Gozon.
**Doctrine:**
1. **Jurisdiction in Mandamus Proceedings:** Under BP 129, the Court of Appeals has concurrent original jurisdiction with the Supreme Court and RTCs to issue writs of mandamus that can include claims for damages.
2. **Public Officers’ Liability for Refusal to Perform Duties:** Articles 27, 2219, and 2217 of the Civil Code allow for moral and exemplary damages against public officers who unjustifiably refuse or neglect to perform their official duties.
3. **Finality and Enforcement of CSC Decisions:** CSC decisions, if uncontested, become final and executory and must be complied with by the involved public officials.
**Class Notes:**
– **Mandamus:** Legal remedy to compel a public officer to perform a duty.
– **BP 129:** Allows CA concurrent jurisdiction with the Supreme Court and RTCs for writs of mandamus.
– **Civil Code Articles:**
– **Art. 27:** Public officers’ liability for refusing official duties.
– **Art. 2217-2219:** Grounds and remedy for moral damages.
– **Art. 2233:** Grounds for awarding exemplary damages.
– **Art. 2208:** Grounds for awarding attorney’s fees.
– **Due Process:** Rights must be observed even in administrative proceedings.
– **Case Precedent:** Final judgments/orders by administrative agencies like CSC bind public officers.
**Historical Background:**
– **Post-1986 People Power Context:** The reorganization under President Corazon Aquino aimed to streamline government functions post-1986 revolution.
– **Police on Public Accountability:** Reflects evolving jurisprudence in affirming administrative rulings and ensuring accountability of public officers.
This detailed case brief ensures comprehension of the legal nuances of this significant SC decision, aiding in understanding procedural adherence and officer accountability in administrative law.
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