MANILA, Philippines — The Supreme Court (SC) has ruled that the presumption of proper mail delivery does not hold when strong evidence disputes it, as it faulted the Civil Service Commission (CSC) for rejecting an appeal based solely on a registry return receipt.

In its decision penned by Associate Justice Samuel Gaerlan released Wednesday, the SC’s Third Division ordered the CSC to revisit its dismissal of an appeal filed by Victoria Labastida, a local official in Saint Bernard, Leyte, who was sacked from service over alleged administrative offenses.

Labastida, the town’s Municipal Planning and Development Officer, was dismissed by the local mayor in June 2016 after Monina Quires accused her of gross neglect of duty and conduct prejudicial to the best interest of the service.

According to the municipality, a copy of the decision dated June 10, 2016, was sent to Labastida by registered mail. The post office’s registry return receipt, marked “refused to accept 06-14-16,” was used as proof of delivery.

However, Labastida denied receiving the document. She claimed she only found out about the decision months later, on March 8, 2017, when the Commission on Audit (COA) issued her a notice of suspension. She filed an appeal with the CSC on March 16, 2017, but the CSC junked it for being filed beyond the 15-day window to appeal administrative rulings.

The Court of Appeals upheld the CSC’s move, citing the presumption that the registry return receipt was properly issued and delivered in the regular course of official duties.

The Supreme Court reversed this. It stressed that legal presumptions under the Rules of Evidence — particularly that official duties are regularly performed and mail is properly delivered — may be rebutted by strong contrary evidence.

“The certification of the postmaster constitutes the best evidence to prove that the mail matter was validly sent,” the Court ruled, emphasizing that a registry return receipt alone is insufficient. The post office must confirm, through an affidavit, the exact details of delivery: when, how, and to whom it was made.

The SC also noted several irregularities supporting Labastida’s claim. The registry return receipt bore the signature of an unnamed postal official and failed to prove personal service to Labastida or any authorized representative. Additionally, the new municipal mayor and the Human Resources Office both testified that they had no records of the dismissal decision or any proceedings leading to it. They too only learned about the case on March 8, 2017.

With this, the SC ruled that Labastida had successfully rebutted the presumption of proper delivery and ordered the CSC to consider the merits of her appeal.