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1. The policy popularly known as “quantum leap” was further reiterated in CSC
MC No. 18, s. 2016. However, it clarified that the three-salary grade rule is not a
deterrent to career advancement because it is allowed in meritorious cases. One of
these meritorious cases where “quantum leap” is allowed can be found in Item 1(e) of
said Resolution, to quote:
2. Relatedly, even before the issuance of CSC Resolution No. 1600732 the
Commission in its previous resolution allowed “quantum leap”. For instance in
Resolution No. 021558, December 11, 2002 in the case of Natividad D Rosalado and
Jesus T Casurao, wherein it emphasized that the phrase "except in very meritorious
cases" does not mean an absolute interpretation of the rule. It is never the intent of the
Commission to frustrate the dreams of a qualified employee to be promoted to a
second level position, by mere expediency of citing Item 15 of CSC MC No. 3, s. 2001.
Likewise, it may be said that the matter is also prejudicial to the discretionary power of
the appointing authority to choose freely according to his/her judgment among qualified
employees whom he/she deems best qualified for any competitive position in the civil
service.
3. Similarly, the High Court in its decision in Abad v. Dela Cruz, G.R. No.
207422, March 18, 2015, upheld the decision of the CSC allowing the appointment of
Herminio Dela Cruz from promotion from a Salary Grade 18 to a Salary Grade 27 after
undergoing a deep selection process and demonstrated his superior qualifications and
competence against other applicants. This is to maintain the standard of merit and
fitness for appointment in the civil service.
4. Further, in its latest ruling in Estrellado and Borja v. David, Se G.R. No.
184288, February 16, 2016 the SC adopted the CSC ruling allowing “quantum leap”
when it held that the three-salary grade limitation should not be the sole basis for the
disapproval of an appointment but should be taken as an indicator of possible abuse of
discretion in the appointment process. The appointment was affirmed because he was
better qualified despite the fact that the appointee was not the next in rank or that his
promotion would require moving him to six-salary grades higher.
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