LL2 CASE DIGEST

Buenaflor vs. Ramirez, Jr.

G.R. No. 201607
Ponente
BERSAMIN, J

Facts:
Jose R. Ramirez, Jr. was appointed as Executive Assistant III and Assistant Accountant by
Chairman Eufemio Domingo of the Presidential Anti-Graft Commission (PAGC) on August 27,
2001.

Chairman Domingo resigned on September 28, 2001, and petitioner Cesar D. Buenaflor
succeeded him.

Buenaflor terminated Ramirez's employment on the same date, claiming that his tenure had
expired as the position of Executive Assistant was personal and confidential, and therefore co-
terminous with the appointing authority.

Ramirez filed a complaint in the Regional Trial Court (RTC) to declare his dismissal null and
void.

Issue:
Whether the Court of Appeals decided the case in accordance with the law and existing
jurisprudence, considering the alleged errors in its findings and the timeliness of the Notice of
Appeal filed by Buenaflor.

Whether the Court of Appeals committed grave abuse of discretion in not declaring that the RTC
has no jurisdiction over the civil service-related case, which falls under the exclusive jurisdiction
of the Civil Service Commission (CSC).

Ruling:
The Supreme Court ruled in favor of Buenaflor, emphasizing that the RTC has no jurisdiction
over cases involving civil service employees.

The Court held that the CSC has exclusive jurisdiction over disciplinary cases and personnel
actions affecting civil service employees, including appointment or separation from the service.

The complaint filed by Ramirez challenged the validity of his termination, which falls under the
jurisdiction of the CSC.

Therefore, the RTC should have dismissed the case for lack of jurisdiction.
The Court also declared that the decisions or orders rendered by courts without jurisdiction are
void and ineffectual.

1. BUENAFLOR VS RAMIREZ LL2 CASE DIGEST.docx 1

Ratio:
The Court based its decision on the jurisdictional provisions of the Administrative Code of 1987,
which vests the CSC with the power to hear and decide administrative cases, including contested
appointments and cases involving civil service employees.

The Court clarified that the mere fact that the parties are members of the Civil Service does not
automatically place the controversy under the special jurisdiction of the CSC.
Jurisdiction over the subject matter is conferred only by the Constitution or the law, and the RTC
cannot arrogate unto itself the hearing and decision of a subject matter outside of its jurisdiction.

The Court also emphasized that a void judgment does not attain finality, and a petition for
certiorari to declare its nullity should not be dismissed for untimeliness.
Therefore, the Court granted the petition for certiorari, annulled the resolutions of the Court of
Appeals, dismissed the case, and ordered the respondent to pay the costs of the suit.

1. BUENAFLOR VS RAMIREZ LL2 CASE DIGEST.docx 2