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	GR No. 203372 2015-06-16	ATTY. CHELOY E. VELICARIA- GARAFIL v. OFFICE OF PRESIDENT CARPIO, J.
SO ORDERED.[37]
	GR No. 181559 2009-10-02	LEAH M. NAZARENO v. CITY OF DUMAGUETE DEL CASTILLO, J.
In Sales v. Carreon, Jr.,[18] we had occasion to discuss the reasons behind the prohibition by the Commission of mass appointments after the elections. Sales involved the issuance of 83 appointments made by then Dapitan City Mayor Joseph Cedrick O. Ruiz in his last month of office (on June 1, 18, and 27, 2001), which the newly elected Mayor, Rodolfo H. Carreon, subsequently revoked, on the ground that these violated CSC Resolution No. 010988 in relation to CSC Memorandum Circular No. 7, Series of 2001, imposing a ban on issuing appointments in the civil service during the election period. In Sales, we declared: This case is a typical example of the practice of outgoing local chief executives to issue "midnight" appointments, especially after their successors have been proclaimed. It does not only cause animosities between the outgoing and the incoming officials, but also affects efficiency in local governance. Those appointed tend to devote their time and energy in defending their appointments instead of attending to their functions.[19]
	GR No. 177736 2008-10-10	MELANIE P. MONTUERTO v. MAYOR ROLANDO E. TY NACHURA, J.
Accordingly, the CSC has the authority to recall the appointment of the petitioner.[7]