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Case Digest: Capablanca v. CSC
ISSUE: Whether or not the CSC can conduct an investigation regarding the irregularity of Capablanca’s CSP-CAT.
FACTS: Eugenio Capablanca was appointed into the PNP with the position of PO1 with temporary status. He passed both the PNP Entrance Examination conducted by the National Police Commission (NAPOLCOM) and the Career Service Professional Examination-Computer Assisted Test (CSP-CAT) given by the Civil Service Commission (CSC) he was subsequently conferred permanent status. The CSC conducted an investigation because of irregularities regarding Capablanca’s CSP-CAT. Capablanca averred that only the NAPOLCOM had sole authority to conduct police entrance exams.
DECISION: Yes. The CSC can conduct an investigation.
RATIO DECIDENDI: The CSC, as the central personnel agency of the Government, is mandated to establish a career service, to strengthen the merit and rewards system, and to adopt measures to promote morale, efficiency and integrity in the civil service. Jurisprudence has held that Appointees to Police Officer and Senior Police Officer positions in the Philippine National Police must have passed any of the following examinations: a) PNP Entrance Examination; b) Police Officer 3rd Class Examination; and c) CSC Police Officer Entrance Examination. The CSC is mandated to conduct the qualifying entrance examination (CSC Police Officer Entrance Examination) for Police Officer 1.