### Facts:
In 1993, Nilo Paloma was appointed as the General Manager of the Palompon, Leyte Water District by its Board of Directors. His tenure was abruptly terminated on December 29, 1995, following Resolution No. 8-95 passed by the Board. In response, Paloma filed a petition for mandamus with the Regional Trial Court (RTC) in January 1996, arguing that his dismissal was executed without due process, constituting a violation of his constitutional rights. The respondents, consisting of the Board members, countered by filing a Motion to Dismiss based on lack of jurisdiction and want of cause of action. The RTC dismissed Paloma’s complaint, citing it as premature. Dissatisfied, Paloma took the matter to the Civil Service Commission (CSC), which eventually ruled in favor of the respondents, leading Paloma to appeal to the Court of Appeals. The appellate court upheld the RTC’s decision, prompting Paloma to escalate the matter to the Supreme Court.
### Issues:
1. Whether mandamus can compel the Board of Directors of a water district to reinstate its General Manager.
2. Whether the Civil Service Commission (CSC) holds primary jurisdiction over cases of illegal dismissal within water districts.
### Court’s Decision:
The Supreme Court denied Paloma’s petition, affirming the decision of the Court of Appeals. The Court highlighted that mandamus cannot be used to compel the performance of a discretionary act, particularly when the law, Presidential Decree (P.D.) No. 198 as amended by P.D. No. 768, clearly states that a general manager serves at the pleasure of the Board. Furthermore, it emphasized the doctrine of primary jurisdiction, which posits that matters requiring specialized administrative expertise fall under the jurisdiction of relevant administrative bodies, such as the CSC in this case. The Supreme Court also noted the mootness of the issue due to the subsequent absorption of the Palompon, Leyte Water District by the local government, and the amendment introduced by Republic Act No. 9286, which altered the terms of the general manager’s removal, cannot be applied retroactively.
### Doctrine:
This case reiterates the doctrine that mandamus cannot compel the performance of a discretionary duty and highlights the principle of primary jurisdiction, showing that courts should not pre-empt the role of administrative bodies in matters falling within the latter’s expertise. The case also demonstrates the non-retroactive application of subsequent legal amendments to pending cases unless explicitly stated.
### Class Notes:
– The principle of mandamus: It cannot be used to compel actions that are discretionary, only those that are ministerial.
– Doctrine of primary jurisdiction: Courts defer to the judgment of administrative agencies on matters requiring technical expertise.
– Non-retroactivity of laws: New laws do not apply retroactively to pending cases unless explicitly provided.
### Historical Background:
The events leading to this Supreme Court decision highlight the complexity of judicial remedies against administrative actions, especially in the context of employment within government-owned and controlled corporations or public utilities in the Philippines. It showcases the evolving legal landscape concerning the employment security of positions that were previously at the discretionary termination by appointing boards or authorities, as evident in the changes introduced by Republic Act No. 9286.
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