CSC vs.

Joson Facts: On July 1995, Ong commenced working as Executive Assistant IV in POEA but appointment by Administrator Joson was approved by CSC in November under a Coterminous Temporary status for not meeting the educational qualification of Bachelors degree. CSC NCR conducted post audit and submitted that appointment was effective July, not November. Joson subsequently requested for the payment of salary of Ong from July to October, which petitioner denied and reversed by CA.

Issue: Whether or not appointment is effective on the date of actual assumption by the appointee considering it precedes approval by CSC.

Ruling: Yes, appointment is effective on the date of actual assumption of office as long as the creation thereof is authorized by law, but should not be earlier than the date of issuance of appointment, which is the date of signing by the appointing authority. Ong was validly appointed as it was done after the approval by DBM of the creation of the contractual position. Hence, she is a de facto officer, entitled to payment of salaries from the day she started working. The subsequent approval by CSC only made her a de jure officer and does not affect the effectivity of her appointment. CA decision is affirmed.