Supreme Court says postmaster’s certification needed to prove failed mail delivery | ABS-CBN
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Supreme Court says postmaster’s certification needed to prove failed mail delivery
Supreme Court says postmaster’s certification needed to prove failed mail delivery
MANILA — The Supreme Court said that a registry return receipt from the post office was insufficient to prove that a letter was properly delivered when there is strong, contrary evidence.
MANILA — The Supreme Court said that a registry return receipt from the post office was insufficient to prove that a letter was properly delivered when there is strong, contrary evidence.
In a decision promulgated on January 27, 2025, the court’s Third Division granted the petition for certiorari filed by Victoria Labastida, the Municipal Planning and Development Officer of Saint Bernard, Southern Leyte in 2013.
In a decision promulgated on January 27, 2025, the court’s Third Division granted the petition for certiorari filed by Victoria Labastida, the Municipal Planning and Development Officer of Saint Bernard, Southern Leyte in 2013.
Labastida faced a complaint of gross neglect of duty and conduct prejudicial to the best interest of the service from Monina Quires over a land use issue.
Labastida faced a complaint of gross neglect of duty and conduct prejudicial to the best interest of the service from Monina Quires over a land use issue.
Quires also accused Labastida of being a disrespectful and arrogant public servant.
Quires also accused Labastida of being a disrespectful and arrogant public servant.
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The Disciplining Authority of the Office of the Mayor eventually held Labastida liable for gross neglect of duty and conduct prejudicial to the best interest of the service.
The Disciplining Authority of the Office of the Mayor eventually held Labastida liable for gross neglect of duty and conduct prejudicial to the best interest of the service.
The decision was supposedly sent to Labastida via registered mail, with a return receipt bearing the annotation “refused to accept” on June 14, 2016.
The decision was supposedly sent to Labastida via registered mail, with a return receipt bearing the annotation “refused to accept” on June 14, 2016.
But Labastida said in her appeal before the Civil Service Commission filed March 16, 2017 that she only received a copy of the decision on March 8, 2017.
But Labastida said in her appeal before the Civil Service Commission filed March 16, 2017 that she only received a copy of the decision on March 8, 2017.
The CSC dismissed the appeal for having been filed beyond the 15-day period.
The CSC dismissed the appeal for having been filed beyond the 15-day period.
The Court of Appeals affirmed the CSC ruling.
The Court of Appeals affirmed the CSC ruling.
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The Supreme Court however disagreed with the CA, stating that mere presentation of registry return receipt was not enough as Labastida denied receiving the decision, which is supported by strong, opposing evidence.
The Supreme Court however disagreed with the CA, stating that mere presentation of registry return receipt was not enough as Labastida denied receiving the decision, which is supported by strong, opposing evidence.
The SC further held that the return receipt should have been accompanied by a postmaster’s affidavit.
The SC further held that the return receipt should have been accompanied by a postmaster’s affidavit.
“The certification of the postmaster constitutes the best evidence to prove that the mail matter was validly sent,” the court said in the decision penned by Associate Justice Samuel Gaerlan.
“The certification of the postmaster constitutes the best evidence to prove that the mail matter was validly sent,” the court said in the decision penned by Associate Justice Samuel Gaerlan.
The SC said Labastida’s claim was supported by key pieces of evidence, such as the certification of the succeeding mayor that neither his office nor the Human Resources Management Office of the municipality that they do not have any record of the alleged decision.
The SC said Labastida’s claim was supported by key pieces of evidence, such as the certification of the succeeding mayor that neither his office nor the Human Resources Management Office of the municipality that they do not have any record of the alleged decision.
The return receipt also bore the signature of an unidentified postal official.
The return receipt also bore the signature of an unidentified postal official.
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The SC however ordered that the case be remanded to the CSC to further resolve the appeal of Labastida.
The SC however ordered that the case be remanded to the CSC to further resolve the appeal of Labastida.
“As Labastida’s Constitutional right to security of tenure hangs by a thread, the ends of justice would best be served if the case is determined on the merits after giving the parties a full opportunity to present their causes and defenses,” the court said.
“As Labastida’s Constitutional right to security of tenure hangs by a thread, the ends of justice would best be served if the case is determined on the merits after giving the parties a full opportunity to present their causes and defenses,” the court said.
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