Rizal Empire Insurance Group vs. National Labor Relations Commission PDF

Rizal Empire Insurance Group vs. National Labor Relations the ground of technicality? Commission 2. Was the dismissal of Rogelio R. Coria by Rizal Case...

Rizal Empire Insurance Group vs. National Labor Relations the ground of technicality? Commission 2. Was the dismissal of Rogelio R. Coria by Rizal Case Empire Insurance Group justified on the grounds of G.R. No. 73140 tardiness and unexcused absences? May 28, 1987 Ruling: 1. The Supreme Court ruled that the NLRC did not Facts: commit a grave abuse of discretion in dismissing the  The case is "Rizal Empire Insurance Group v. National Labor Relations Commission." petitioners' appeal for being filed out of time.  Petitioners: Rizal Empire Insurance Group and Sergio 2. The Supreme Court upheld the decision of the Labor Corpus. Arbiter, ruling that the dismissal of Rogelio R. Coria  Respondents: National Labor Relations Commission was illegal. (NLRC), Labor Arbiter Teodorico L. Ruiz, and Rogelio R. Ratio: Coria.  The Revised Rules of the National Labor Relations  Rogelio R. Coria was hired as a casual employee in August Commission are clear and explicit, leaving no room 1977 with a daily wage of P10.00. for interpretation.  On January 1, 1978, Coria became a regular employee and  Rule VIII, Section 1(a) states that decisions or orders was appointed as a clerk-typist with a monthly salary of of a Labor Arbiter are final and executory unless P300.00. appealed within ten calendar days from receipt of  Coria received several promotions and salary increases, notice. becoming an inspector in the Fire Division by July 1983  Section 6 explicitly states that no extension of the with a monthly salary of P685.00 plus allowances and period to perfect an appeal shall be entertained. other benefits.  Petitioners received the Labor Arbiter's decision on  On October 15, 1983, Coria was dismissed for tardiness and unexcused absences. April 1, 1985, and filed a Motion for Extension of Time to File Memorandum of Appeal on April 11,  Coria filed a complaint with the Ministry of Labor and Employment (MOLE). 1985, followed by the actual filing of the  On March 14, 1985, Labor Arbiter Teodorico L. Ruiz ruled Memorandum of Appeal on April 22, 1985. in favor of Coria, ordering his reinstatement with back  Given the "no extension policy," the NLRC correctly wages. dismissed the appeal for being filed out of time.  Petitioners appealed to the NLRC, but the appeal was  Administrative regulations and policies enacted by dismissed on November 15, 1985, for being filed out of administrative bodies to interpret the law they are time. entrusted to enforce have the force of law and are  Petitioners brought the case to the Supreme Court, entitled to great respect. arguing that the NLRC committed a grave abuse of  The consistent promotions and salary increases of discretion by dismissing their appeal on a technicality. Coria indicated his efficiency as a worker. Issue:  Occasional lapses in punctuality and attendance did 1. Did the National Labor Relations Commission commit not justify his dismissal. a grave abuse of discretion amounting to lack of  The Labor Arbiter's ruling was correct, and the jurisdiction by dismissing the petitioners' appeal on petition was dismissed  2. Do the executive orders violate the constitutional Anak Mindanao Party-List Group vs. Executive principles of separation of powers and the rule of Secretary law? Case 3. Do the executive orders infringe upon the G.R. No. 166052 constitutional rights of the people and their Decision Date organizations to effective and reasonable Aug 28, 2007 participation in decision-making? Facts: Ruling:  The case involves a petition for certiorari and 1. The Supreme Court ruled that the President has the prohibition with a prayer for injunctive relief filed authority to reorganize the Department of Agrarian by Anak Mindanao Party-List Group (AMIN) and Reform and place the PCUP and NCIP under its Mamalo Descendants Organization, Inc. (MDOI). control through executive orders.  Petitioners challenged the constitutionality of 2. The Court found that the executive orders did not Executive Order (E.O.) Nos. 364 and 379, issued in violate the constitutional principles of separation of 2004 by President Gloria Macapagal-Arroyo. powers and the rule of law.  E.O. No. 364 transformed the Department of Agrarian 3. The Court held that the executive orders did not Reform (DAR) into the Department of Land Reform infringe upon the constitutional rights of the people (DLR) and placed the Presidential Commission for and their organizations to effective and reasonable the Urban Poor (PCUP) and the National Commission participation in decision-making. on Indigenous Peoples (NCIP) under its supervision Ratio: and control.  The Supreme Court emphasized that the President  E.O. No. 379 amended E.O. No. 364 by making the has broad powers to reorganize the offices under her NCIP an attached agency of the DLR. supervision and control, as provided by the  Petitioners argued that these executive orders Constitution and the Administrative Code of 1987. violated constitutional principles, including the  The President's power of control includes the separation of powers, the rule of law, and the authority to transfer functions and agencies to constitutional scheme for agrarian reform, urban achieve simplicity, economy, and efficiency in the land reform, and indigenous peoples' rights. delivery of social reforms.  The issue of transforming the DAR into the DLR  The PCUP and NCIP were created as agencies under became moot due to E.O. No. 456, which reverted the the Office of the President, giving the President the department to its former name on August 23, 2005. authority to reorganize them.  The remaining issue was the legality of placing the  The Court rejected the argument that the PCUP and NCIP under the DLR. reorganization required legislative action, stating Issue: that the President's power to reorganize is not 1. Does the President have the authority to reorganize limited by the need for new legislation. the Department of Agrarian Reform and place the  Petitioners failed to demonstrate a clear and PCUP and NCIP under its control through executive unequivocal breach of the Constitution. orders?  The Court addressed the issue of legal standing,  concluding that AMIN had the requisite standing as the PNRC is a private organization performing a member of Congress, but MDOI did not have a public functions and is not a GOCC. direct and personal interest in the case.  The Court also declared void certain sections of the  The Court dismissed the claim that the executive PNRC Charter (Republic Act No. 95) that created the orders violated the people's right to participation in PNRC as a private corporation. decision-making, stating that the role of the State is  This decision led to motions for reconsideration and to facilitate, not necessarily create, consultation clarification from Gordon and the PNRC, arguing mechanisms. that the constitutionality of R.A. No. 95 was not  The Court concluded that the executive orders were raised by the parties and should not have been not unconstitutional and dismissed the petition. decided by the Court. Liban vs. Gordon Case Issue: G.R. No. 175352  Did Richard J. Gordon forfeit his seat in the Senate Decision Date by accepting the chairmanship of the PNRC Board of Jan 17, 2011 Governors?  Was the Supreme Court correct in declaring certain Facts: sections of the PNRC Charter void for creating the  The case of Liban v. Gordon (G.R. No. 175352) was PNRC as a private corporation? Ruling: decided by the Supreme Court of the Philippines on  The Supreme Court ruled that Richard J. Gordon did January 18, 2011. not forfeit his seat in the Senate when he accepted  Petitioners Dante V. Liban, Reynaldo M. Bernardo, the chairmanship of the PNRC Board of Governors. and Salvador M. Viari sought to declare that  The Supreme Court reconsidered its earlier decision respondent Richard J. Gordon forfeited his Senate and ruled that the constitutionality of R.A. No. 95, as seat by accepting the chairmanship of the Philippine amended, was not raised by the parties and should National Red Cross (PNRC) Board of Governors. not have been passed upon by the Court. The PNRC  The PNRC intervened in the case. Charter remains valid and constitutional in its  Petitioners argued that Gordon's acceptance of the entirety. PNRC chairmanship violated Section 13, Article VI Ratio: of the 1987 Constitution, which prohibits Senators  The Supreme Court reiterated that the PNRC is a from holding any other office or employment in the private organization performing public functions government or any government-owned or controlled and is not a GOCC. Therefore, Gordon's acceptance of corporation (GOCC). the PNRC chairmanship did not violate Section 13,  The lower court had not ruled on the matter, and Article VI of the 1987 Constitution. the case was brought directly to the Supreme Court.  The Court emphasized the PNRC's unique status as a  On July 15, 2009, the Supreme Court initially ruled National Society of the International Red Cross and that Gordon did not forfeit his Senate seat because Red Crescent Movement, which requires it to be  independent and neutral, further supporting its  Respondents include the City of Pasay, Sangguniang classification as a private entity. Panglungsod ng Pasay, City Mayor of Pasay, City  Regarding the constitutionality of the PNRC Charter, Treasurer of Pasay, and City Assessor of Pasay. the Court acknowledged that the issue was not  MIAA operates the Ninoy Aquino International raised by the parties and was not the very lis mota of the case. Airport (NAIA) Complex under Executive Order No.  The Court cited the principle that it should not pass 903 (EO 903) issued on July 21, 1983, by President upon a constitutional question unless it is Ferdinand E. Marcos. unavoidable.  The NAIA Complex spans approximately 600  The Court recognized the PNRC's sui generis status, hectares and includes runways, the airport tower, meaning it is neither strictly private nor public in and other buildings. nature.  On August 28, 2001, MIAA received Final Notices of  The PNRC's creation was driven by the Philippines' adherence to the Geneva Conventions and its role as Real Property Tax Delinquency from the City of an auxiliary to the government in the humanitarian Pasay for the years 1992 to 2001, totaling PHP field. 1,016,213,836.33.  The Court concluded that the PNRC Charter does not  The City of Pasay issued notices of levy and violate the constitutional prohibition against the threatened to auction the NAIA Pasay properties if creation of private corporations by special law, as it the taxes were not paid. serves the public good and fulfills international treaty obligations.  MIAA filed a petition for prohibition and injunction  The decision to reconsider the earlier ruling and with the Court of Appeals to stop the City of Pasay uphold the validity of the PNRC Charter was from imposing real property taxes and auctioning influenced by the potential negative consequences the properties. of declaring the Charter void, including the  The Court of Appeals dismissed the petition, disruption of the PNRC's humanitarian work and the affirming the City of Pasay's authority to impose adverse impact on the Philippines' international and collect realty taxes. obligations and reputation. MIAA vs. City of Pasay  MIAA's motion for reconsideration was denied, Case leading to this petition for review on certiorari. G.R. No. 163072 Issue: Decision Date 1. Are the NAIA Pasay properties of MIAA exempt Apr 1, 2009 from real property tax? Facts: 2. Does the Local Government Code withdraw the tax  The Manila International Airport Authority (MIAA) exemption previously granted to MIAA under EO is the petitioner. 903?  2(10) of the Introductory Provisions of the Administrative Code of 1987 includes government- Ruling: owned or controlled corporations, indicating that a  The Supreme Court ruled in favor of MIAA. government instrumentality may or may not be a  The NAIA Pasay properties are exempt from real GOCC. property tax imposed by the City of Pasay, except  MIAA, being neither a stock nor a non-stock for portions leased to private parties. corporation, does not qualify as a GOCC but remains  The Court set aside the Decision dated October 30, a government instrumentality exercising both 2002, and the Resolution dated March 19, 2004, of governmental and corporate powers. the Court of Appeals in CA-G.R. SP No. 67416.  Therefore, MIAA is exempt from any kind of tax  All real property tax assessments and final notices from local governments, including real property tax, of real property tax delinquencies issued by the except for portions leased to private parties. City of Pasay on the NAIA Pasay properties were declared void, except for portions leased to private parties. Ratio: Title  MIAA is a government instrumentality vested with Busacay vs. Buenaventura corporate powers and performing essential public Case services, not a government-owned or controlled G.R. No. L-5856 corporation (GOCC). Decision Date  As a government instrumentality, MIAA is not Sep 22, 1953 subject to any kind of tax by local governments Facts: under Section 133(o) of the Local Government Code.  Marcelino A. Busacay was a pre-war toll collector at  The exception to the exemption in Section 234(a) the Bued toll bridge in Sison, Pangasinan, with a does not apply to MIAA because it is not a taxable permanent appointment. entity under the Local Government Code.  After the liberation in 1945, Busacay was  Airport lands and buildings of MIAA are properties reappointed to his position. devoted to public use and are thus properties of  In November 1947, the Bued toll bridge was public dominion, exempt from real estate tax under destroyed by a flood, leading to the layoff of Busacay Section 234(a) of the Local Government Code. and two other toll collectors.  Portions of the NAIA Pasay properties leased to  The bridge had been temporarily closed for minor private parties are subject to real property tax. repairs from July to September 1946, during which  The definition of "instrumentality" under Section time Busacay and his colleagues were not paid.   Upon the bridge's reopening, they resumed work the toll collector positions, as the bridge was without new appointments until the bridge's essential and its reconstruction was anticipated. destruction.  The destruction of the bridge only suspended the  When the bridge was reconstructed and reopened in positions, and upon its rehabilitation, the toll November 1950, Busacay sought to resume his collector's right to the position was automatically duties. restored.  The Provincial Treasurer refused to reinstate him,  The Court cited precedents where pre-war officers appointing Alfredo Murao instead. were allowed to reoccupy their positions post-  Busacay filed for mandamus and quo warranto, liberation without new appointments. seeking reinstatement, back pay, and damages.  Judgments must be responsive to the pleadings and  The Court of First Instance of Pangasinan dismissed cannot adjudicate against parties not involved in the his application for lack of merit, leading to this case. appeal.  The Provincial Treasurer could not be held Issue: personally liable without proof of bad faith. 1. Were the positions of toll collectors abolished by the  Any declaration affecting non-parties would be total destruction of the Bued toll bridge in 1947? unfair and prejudicial 2. Is the toll collector entitled to back salary and/or damages? Banda vs. Ermita Ruling: Case 1. The Supreme Court ruled that the position of toll G.R. No. 166620 collector was not abolished but merely suspended Decision Date due to the destruction of the bridge. Therefore, Apr 19, 2010 Busacay should be reinstated to his position. Facts: 2. The claim for back salary and/or damages was  Case Title: Banda v. Ermita (G.R. No. 166620) denied. The Provincial Treasurer is not personally  Decision Date: April 20, 2010 liable, nor authorized to pay from public funds  Ponente: Justice Leonardo-De Castro without proper authorization by the Provincial  Petitioners: Group of National Printing Office (NPO) Board, which was not a party to the suit. Ratio: employees led by Atty. Sylvia Banda  For an office to be considered abolished, there must  Challenged Order: Executive Order No. 378 be an intention to do away with it wholly and  Issued By: President Gloria Macapagal-Arroyo on permanently. October 25, 2004  There was no intention to permanently eliminate  Amended Order: Executive Order No. 285 issued by  former President Corazon C. Aquino in 1987. continuing authority to reorganize the  Original Provision: Granted NPO exclusive administrative structure of the Office of the jurisdiction over printing government forms, official President to achieve simplicity, economy, and ballots, and public documents. efficiency.  Amendment Impact: Removed NPO's exclusivity,  Previous cases like Buklod ng Kawaning EIIB v. allowing private sector competition for government Zamora and Larin v. Executive Secretary affirm the printing jobs, except for election paraphernalia. President's authority to reorganize executive offices.  Petitioners' Argument: Executive Order No. 378  The reorganization must be done in good faith and threatened their job security and exceeded the for the purpose of improving efficiency and President's executive authority. economy.  Procedural Issue: Initial class suit faced  There was no evidence that the reorganization was representation adequacy and employee support done in bad faith or for political reasons. issues.  Limiting the NPO's budget to its own income and Issue: opening government printing jobs to private sector 1. Can President Arroyo amend or repeal Executive competition were consistent with state policies to Order No. 285 through the issuance of Executive encourage competitiveness and efficiency in Order No. 378? government procurement, as outlined in Republic 2. Does Executive Order No. 378 violate the security of Act No. 9184 (Government Procurement Reform tenure of NPO employees by potentially leading to Act). the gradual abolition of the NPO?  Therefore, Executive Order No. 378 was a valid Ruling: exercise of the President's delegated legislative 1. The Supreme Court ruled that President Arroyo has power to reorganize the executive branch the authority to amend or repeal Executive Order No. 285 through Executive Order No. 378. Crisostomo vs. Court of Appeals 2. The Court found that Executive Order No. 378 does Case not violate the security of tenure of NPO employees G.R. No. 106296 and dismissed the petition. Decision Date Ratio: Jul 4, 1996  The President has the power to reorganize the Facts: executive branch, including the NPO, under the  Appointment and Charges: Isabelo T. Crisostomo was 1987 Administrative Code and other relevant laws. appointed President of the Philippine College of  Section 31, Chapter 10, Title III, Book III of the Commerce (PCC) on July 17, 1974. He faced Administrative Code of 1987 grants the President administrative cases for illegal use of government  vehicles, misappropriation of construction materials, President Corazon C. Aquino appointed Dr. Jaime oppression, harassment, grave misconduct, nepotism, Gellor as acting president of PUP. and dishonesty.  Court of Appeals Ruling: The Court of Appeals  Investigation and Charges: The cases were referred issued a temporary restraining order against to the Office of the Solicitor General for Crisostomo's reinstatement and later ruled that the investigation. Charges of violating R.A. No. 3019 PCC was abolished and replaced by PUP, thus (Anti-Graft and Corrupt Practices Act), R.A. No. 992, denying Crisostomo's reinstatement but allowing and R.A. No. 733 were filed against him with the recovery of salaries and benefits up to the Office of the Tanodbayan. conversion date.  Informations Filed: On June 14, 1976, three Issue: informations for violation of Sec. 3(e) of R.A. No. 1. Abolition or Conversion: Was the Philippine College 3019 were filed, alleging Crisostomo appropriated a of Commerce (PCC) abolished or merely converted bahay kubo and construction materials worth into the Polytechnic University of the Philippines P250,000.00 and used a college driver for personal (PUP)? purposes. 2. Entitlement to Reinstatement and Benefits: Is  Suspension and Replacement: He was preventively Isabelo T. Crisostomo entitled to reinstatement as suspended on October 22, 1976, and Dr. Pablo T. President of PUP and to the payment of salaries and Mateo, Jr. was designated as officer-in-charge and benefits during his suspension? later as Acting President. Ruling:  Conversion to PUP: On April 1, 1978, P.D. No. 1341 1. Conversion: The PCC was not abolished but merely converted the PCC into the Polytechnic University converted into PUP. of the Philippines (PUP). Mateo continued as the 2. Entitlement to Benefits: Crisostomo is not entitled to head of the new university and was appointed reinstatement as President of PUP but is entitled to President for a six-year term on March 28, 1980. retirement benefits or separation pay. He is also  Acquittal and Reinstatement Order: Crisostomo was entitled to salaries and benefits up to March 28, acquitted of all charges on July 11, 1980, and 1980, when his term was terminated. ordered reinstated with entitlement to back salaries Ratio: and benefits. The administrative cases were  Legal Interpretation of P.D. No. 1341: The Supreme dismissed for lack of prosecution, and the Court held that P.D. No. 1341 did not abolish the PCC Tanodbayan cases were dismissed as moot. but merely changed its academic status to PUP,  Motion for Execution: Crisostomo filed a motion for similar to the earlier conversion of the Philippine execution of the judgment in 1992, which was School of Commerce into PCC by R.A. No. 778. granted by the Regional Trial Court. Despite this,  Nature of Change: The change involved a new name,  expanded curricular offerings, and structural  The case "Seton v. Rodriguez" involves a dispute reorganization, but not the creation of a new over the surrender of a duplicate certificate of title institution. for annotating a deed of sale.  Requirement for Abolition: The Court emphasized  Petitioners Jose Seton and Juliana Seton hold the that an express declaration by the lawmaking original certificate of title No. RO-783 (O-244), authority is required to abolish an institution. issued in the names of their deceased parents,  Reinstatement and Termination: Crisostomo's Baldomero Seton and Severa Quimada. reinstatement was not possible due to P.D. No. 1437,  Respondents are Judge Jose S. Rodriguez of the which fixed the term of office for presidents of state Court of First Instance (Branch IV) of Cebu and universities and colleges at six years, renewable for Ignacio Seton. another term, and authorized the President of the  Baldomero and Severa died intestate in 1918 and Philippines to terminate incumbents not 1940, respectively, leaving four children, including reappointed. the petitioners and their siblings Andrica and  Effect of Mateo's Appointment: Dr. Mateo's Jacinto, as legitimate heirs. appointment as President of PUP for a six-year term  On May 29, 1959, Jacinto's son, Ignacio Seton, filed a on March 28, 1980, effectively terminated complaint for partition of the real estate left by the Crisostomo's term. deceased spouses, claiming he acquired his father's  Entitlement to Benefits: Therefore, Crisostomo was rights and interests in the property through a entitled only to retirement benefits or separation purchase on June 10, 1952. pay as per P.D. No. 1437, Section 7.  On June 3, 1959, Ignacio filed a motion in another  Modification of Court of Appeals' Decision: The branch of the Court of First Instance of Cebu, Court modified the Court of Appeals' decision, requesting Jose and Juliana to surrender the setting aside the orders for Crisostomo's owner's duplicate certificate of title for annotating reinstatement and payment of salaries and benefits the deed of sale executed by his father in his favor. accruing after March 28, 1980, and remanded the  Jose and Juliana opposed the motion, arguing that case to the trial court to determine the amounts due the lots had already been partitioned and that the up to that date. deed of sale was fictitious, false, and fraudulent. Seton vs. Rodriguez They also cited the pendency of the partition action Case as a reason to delay the annotation. G.R. No. L-16285  Despite their opposition, the respondent judge Decision Date issued an order on September 15, 1959, requiring Dec 28, 1960 the surrender of the certificate for annotation. Facts:  The petitioners' appeal was dismissed, leading them  to file a petition for certiorari with preliminary recorded instrument. injunction in the Supreme Court.  The validity or effect of the instrument can only be Issue: determined in an ordinary case before the courts, 1. Whether the order requiring the surrender of the not by a court acting merely as a registration court. duplicate certificate of title for annotation is  The Court further explained that the pendency of appealable. partition proceedings does not preclude the 2. Whether the lower court erred in ordering the registration of the sale, as both cases can proceed surrender of the duplicate certificate of title for the independently. annotation of the deed of sale despite the pendency  If the sale is later adjudged invalid, its annotation of partition proceedings. can be canceled, and if found frivolous or vexatious, Ruling: the court may tax the adverse claimant double or 1. The Supreme Court ruled that the order requiring treble costs at its discretion. the surrender of the duplicate certificate of title for  Therefore, the lower court did not err or abuse its annotation is indeed appealable. discretion in ordering the surrender of the 2. The Supreme Court affirmed the lower court's order duplicate certificate of title for annotation. requiring the surrender of the duplicate certificate of title for the annotation of the deed of sale in favor Eugenio vs. Civil Service Commission of Ignacio Seton. Case G.R. No. 115863 Ratio: Decision Date  The Supreme Court clarified that an order of the Mar 30, 1995 registration court requiring the holder of a Facts: duplicate certificate of title to surrender it for the  Petitioner: Aida D. Eugenio, Deputy Director of the Philippine purpose of annotating an attachment, lien, or Nuclear Research Institute. adverse claim under Section 72 of Act 496 is  Application for Career Executive Service (CES): Eugenio applied for CES Eligibility and a CESO rank. appealable because it resolves important questions  CES Eligibility Granted: Granted CES eligibility on August 2, 1993. regarding the respective rights of the parties.  Recommendation for CESO Rank: Recommended for a CESO rank  The Court emphasized that registration is a to the President by the Career Executive Service Board (CESB) on ministerial act intended to inscribe a deed, contract, September 15, 1993. or instrument in the records of the Office of the  CSC Resolution No. 93-4359: On October 1, 1993, the Civil Service Register of Deeds and annotate it at the back of the Commission (CSC) issued Resolution No. 93-4359, abolishing the certificate of title. CESB and integrating it into the CSC as the Office for Career Executive Service.  The purpose of registration is to give notice to all  Interference with Appointment: This resolution hindered persons and does not determine the validity of the Eugenio's appointment as Civil Service Officer, Rank IV.   Advice for Judicial Relief: On June 7, 1994, Eugenio received be read with Section 16, which lists the offices under the CSC's advice from the Chief Presidential Legal Counsel to seek judicial control. relief.  Autonomous Entity: The CESB, as an autonomous entity  Petition Against Resolution: Eugenio filed a petition to annul administratively attached to the CSC, was not within the CSC's Resolution No. 93-4359, arguing that the CSC usurped legislative power to abolish. functions by abolishing the CESB and authorizing the transfer of  Policy and Program Coordination: The Court clarified that public money without legislative approval. attaching functionally inter-related government agencies is for  Support from Solicitor General: The Solicitor General supported policy and program coordination, not for placing one agency Eugenio's contentions. under another's control.  CSC's Defense: The CSC defended its resolution, claiming  Dismissal of Datumanong Case: The Court dismissed the CSC's authority under the Administrative Code of 1987. reliance on Datumanong, et al. vs. Civil Service Commission, as it Issue: was dismissed for lack of standing and did not address the 1. Authority to Abolish CESB: Did the Civil Service Commission substantive issue of the CSC's authority to abolish the CESB. (CSC) have the authority to abolish the Career Executive Service Board (CESB), an office created by law, through the issuance of CSC Resolution No. 93-4359? 2. Usurpation of Legislative Functions: Did the CSC usurp the Ynot vs. Intermediate Appellate Court legislative functions of Congress by authorizing the transfer of Case public money through the issuance of CSC Resolution No. 93-4359? G.R. No. 74457 Ruling: 1. Lack of Authority: The Supreme Court ruled that the CSC did not Decision Date have the authority to abolish the CESB, as it was an office created Mar 19, 1987 by law and could only be abolished by the legislature. Facts: 2. Annulment of Resolution: The Supreme Court annulled and set  Restituto Ynot transported six carabaos from aside CSC Resolution No. 93-4359, finding that the CSC had indeed usurped the legislative functions of Congress. Masbate to Iloilo on January 13, 1984. Ratio:  The carabaos were seized by the police station  Legislative Functions: The Supreme Court emphasized that the commander of Barotac Nuevo, Iloilo. creation and abolition of public offices are primarily legislative  The seizure was based on Executive Order No. 626-A, functions. issued by President Ferdinand E. Marcos, which  Creation of CESB: The CESB was created by Presidential Decree No. aimed to prevent the slaughter of carabaos and 1 on September 1, 1974, through the Integrated Reorganization Plan and could only be abolished by legislative action. conserve them for agriculture by prohibiting their  Consistent Funding: The legislature consistently allocated funds interprovincial movement. for the CESB's operation in the General Appropriations Acts from  Ynot filed a suit to recover his carabaos, resulting in 1975 to 1993, indicating its continued existence and necessity. the Regional Trial Court of Iloilo City issuing a writ  Misplaced Reliance on Administrative Code: The CSC's reliance on of replevin after he posted a P12,000.00 supersedeas Section 17, Chapter 3, Subtitle A, Title I, Book V of the Administrative Code of 1987 was misplaced. This provision must bond.   The trial court upheld the seizure and ordered the  The Court stressed that due process includes the forfeiture of the bond when the carabaos could not right to notice and a hearing, which the executive be produced. order did not provide.  The trial court did not rule on the executive order's  The prohibition on the interprovincial movement of constitutionality, assuming its validity. carabaos was not reasonably connected to  Ynot appealed to the Intermediate Appellate Court, preventing their slaughter, as carabaos could be which affirmed the trial court's decision. slaughtered in any province.  Ynot petitioned the Supreme Court, arguing that the  The executive order was criticized for arbitrarily executive order was unconstitutional on the delegating authority to administrative officials to grounds of due process and improper exercise of distribute confiscated property without clear legislative power by the President under guidelines, resulting in an invalid delegation of Amendment No. 6 of the 1973 Constitution. legislative powers. Issue:  The order overstepped judicial functions by enabling 1. Is Executive Order No. 626-A unconstitutional for executive authorities to determine guilt and impose authorizing the outright confiscation of carabaos or penalties without a trial. carabeef without due process?  The police station commander acted under the 2. Did the President improperly exercise legislative presumptively valid executive order and was not power under Amendment No. 6 of the 1973 held liable for damages. Constitution in issuing Executive Order No. 626-A?  The decision highlighted the significance of due process and the separation of powers in safeguarding individual rights against arbitrary Ruling: state actions. 1. The Supreme Court declared Executive Order No. Soriano vs. Laguardia 626-A unconstitutional. Case 2. The Court affirmed that the police station G.R. No. 164785 commander who confiscated Ynot's carabaos was not Decision Date liable for damages. Apr 28, 2009 Ratio: Facts:  The Supreme Court deemed Executive Order No. 626  Parties Involved: Eliseo F. Soriano, host of "Ang -A violated due process by allowing immediate Dating Daan," and Ma. Consoliza P. Laguardia, confiscation of carabaos or carabeef without an Chairperson of the MTRCB. opportunity for the owner to be heard before a  Incident: On August 10, 2004, Soriano made competent and impartial court. offensive remarks on his program aired on UNTV 37,  targeting Michael M. Sandoval, a minister of Iglesia 3. Rights Not Violated: The Court ruled that the ni Cristo (INC). suspension did not violate Soriano's rights to equal  Complaints: Complaints were filed by Sandoval and protection, freedom of religion, and freedom of other INC members. speech and expression.  MTRCB Action: On August 16, 2004, the MTRCB Ratio: issued a preventive suspension order, suspending  Implied Authority: The Supreme Court reasoned "Ang Dating Daan" for 20 days. that the MTRCB's authority to issue preventive  Petition for Certiorari: Soriano sought suspension orders is implied in its regulatory and reconsideration and filed a petition with the supervisory powers under PD 1986. Supreme Court to nullify the suspension.  Preventive Measures: Administrative agencies like  Extension of Suspension: On September 27, 2004, the MTRCB have the power to take necessary MTRCB extended the suspension to three months. actions to enforce their mandates, including  Consolidation of Petitions: Soriano filed another preventive measures. petition challenging the extended suspension,  Nature of Suspension: Preventive suspension is not leading the Supreme Court to consolidate the two a penalty but a preliminary step in an petitions for review. administrative investigation. Issue:  No Discrimination: Regarding Soriano's claims, the 1. Validity and Constitutionality: Is the preventive Court found no evidence of discriminatory suspension order issued by the MTRCB against "Ang treatment or religious persecution. Dating Daan" valid and constitutional?  Reasonable Restriction: Soriano's offensive remarks 2. Authority of MTRCB: Does the MTRCB have the did not constitute protected religious speech, and authority to issue preventive suspension orders the suspension was a reasonable restriction to under PD 1986? protect public interest and the welfare of children. 3. Rights Violations: Does the suspension violate  Balancing Interests: The government's interest in Soriano's rights to equal protection, freedom of regulating broadcast content to protect children religion, and freedom of speech and expression? outweighed Soriano's right to free speech in this Ruling: context. 1. Preventive Suspension Order: The Supreme Court Radio Communications of the Philippines, Inc. vs. National upheld the MTRCB's preventive suspension order, Telecommunications Commission ruling it valid and constitutional. Case 2. Authority under PD 1986: The Court affirmed that G.R. No. 93237 the MTRCB has the implied authority under PD 1986 Decision Date to issue preventive suspension orders. Nov 5, 1992 Facts:  The Supreme Court ruled that the NTC lacks  Petitioner: Radio Communications of the Philippines, jurisdiction to impose fines on RCPI for deficient Inc. (RCPI). service.  Respondents: National Telecommunications  The NTC's decision was reversed and set aside. Commission (NTC) and Juan A. Alegre.  The temporary restraining order issued on June 18,  Incident: On March 17, 1989, Dr. Jimena Alegre sent 1990, was made permanent. two urgent telegrams via RCPI's facilities in Manila. Ratio:  Destination: The telegrams were sent to Valencia,  The decision was based on the interpretation of Bohol, and Espiritu, Ilocos Norte with the message Executive Order No. 546 and the Public Service Act "MANONG POLING DIED INTERMENT TUESDAY." (Commonwealth Act No. 146).  Issue: The telegrams did not arrive on the expected  Executive Order No. 546 does not explicitly grant dates. the NTC the power to impose administrative fines on  Complaint: Juan A. Alegre filed a complaint with the public service utilities. NTC, claiming poor service and seeking sanctions  The NTC, as the successor to the Board of against RCPI. Communications, inherited its powers but did not  Proceedings: The NTC acknowledged the complaint gain additional authority to impose fines. and scheduled hearings despite RCPI's objections  The Globe Wireless Ltd. vs. Public Service based on lack of jurisdiction and due process Commission case established that the Public Service concerns. Commission (and by extension, the NTC) cannot  NTC's Decision: The NTC ruled against RCPI, finding impose fines for deficient service. it administratively liable and imposing a PHP 1,000  Administrative agencies have only the powers fine. expressly granted or necessarily implied by the  Reconsideration: RCPI's motion for reconsideration legislation creating them. was denied, leading to the petition for review.  Any order beyond an agency's jurisdiction is void.  Jurisdiction Contest: RCPI contested the NTC's  The proper recourse for aggrieved parties is to file jurisdiction to impose fines, referencing Section the appropriate action in the proper forum. 19(a) of Commonwealth Act No. 146. Malaga vs. Penachos, Jr. Issue: Case 1. Does the National Telecommunications Commission G.R. No. 86695 (NTC) have the jurisdiction to impose fines on RCPI Decision Date for deficient service? Sep 2, 1992 Ruling: Facts:   Petitioners: Maria Elena Malaga (B.E. Construction), the bidding process that justified the issuance of a Josieleen Najarro (Best Built Construction), Jose N. restraining order and the awarding of nominal Occeña (The Firm of Jose N. Occeña), and Iloilo damages to the petitioners? Builders Corporation. Ruling:  Respondents: Manuel R. Penachos, Jr., Alfredo 1. P.D. 1818: The Supreme Court ruled that P.D. 1818 Matangga, Enrico Ticar, Teresita Villanueva does not apply to the ISCOF in this case, allowing the (members of the Pre-qualification Bids and Awards issuance of a restraining order. Committee (PBAC) of the Iloilo State College of 2. Irregularities: The Court found that there were Fisheries (ISCOF)), and Benigno Panistante indeed irregularities in the bidding process, (President of ISCOF). justifying the issuance of a restraining order and  Dispute: Bidding process for the construction of the awarding nominal damages to the petitioners. Micro Laboratory Building at ISCOF. Ratio:  Publication: PBAC published an Invitation to Bid in  Coverage: ISCOF, as a chartered institution, is the Western Visayas Daily on November 25, 26, and covered by P.D. 1818. 28, 1988.  Judicial Scrutiny: P.D. 1818 does not shield  Deadlines: Pre-qualification documents (PRE-C1) on administrative irregularities from judicial scrutiny. December 2, 1988, and opening of bids on December  Cited Case: Datiles and Co. vs. Sucaldito, allowing 12, 1988. courts to intervene in administrative acts involving  Changes: PBAC changed deadlines without proper questions of law. notice, leading to petitioners' disqualification.  Irregularities: PBAC changed deadlines for pre-  Complaint: Petitioners filed a complaint with the qualification and bid submission without proper Regional Trial Court of Iloilo, which issued a notice, and plans and specifications were not issued restraining order against the PBAC. on time.  Motion: PBAC moved to lift the restraining order,  Violations: Rules implementing P.D. 1594, which aim citing Presidential Decree (P.D.) 1818. to ensure competitive bidding and prevent  Trial Court: Lifted the restraining order, leading to favoritism, collusion, and fraud. petitioners' appeal to the Supreme Court.  Procedural Lapses: Rendered the bidding process Issue: void. 1. Application of P.D. 1818: Does P.D. 1818 apply to the  Court Decision: Upheld the restraining order and ISCOF, thereby prohibiting the issuance of a awarded nominal damages of P10,000 each to restraining order or preliminary injunction in this petitioners B.E. Construction and Best Built case? Construction. 2. Bidding Irregularities: Were there irregularities in  Dismissal: Claim of Occeña Builders dismissed for  submitting documents after the deadline. certiorari with the Supreme Court.  Removal: Ordered removal of PBAC members for Issue: malfeasance in office.  Whether PHILHEALTH's strict enforcement of the  Ombudsman: Directed that a copy of the decision be 60-day filing rule for claims is justified. sent to the Office of the Ombudsman.  Whether CGH failed to exhaust administrative Philippine Health Insurance Corp. vs. Chinese General remedies before seeking judicial intervention. Hospital and Medical Center Ruling: Case  The Supreme Court affirmed the decision of the G.R. No. 163123 Court of Appeals, ordering PHILHEALTH to pay Decision Date CGH's claims amounting to P14,291,568.71. Apr 14, 2005  The Court held that CGH was not required to Facts: exhaust administrative remedies due to the public  The case involves the Philippine Health Insurance interest involved and the estoppel of PHILHEALTH. Corporation (PHILHEALTH) as the petitioner and Ratio: the Chinese General Hospital and Medical Center  The Supreme Court emphasized the state policy (CGH) as the respondent. under RA 7875 and the 1987 Philippine  The dispute arose from CGH's claims for services Constitution to provide affordable medical care to all rendered to patients from 1989 to 1992, which citizens, especially the underprivileged. PHILHEALTH denied for being filed beyond the 60-  The Court noted that the 60-day filing rule, while day period prescribed by the Implementing Rules having the force of law, should not be rigidly and Regulations (IRR) of Republic Act No. 7875. enforced to the detriment of health care providers  CGH, an accredited health care provider, had who have already rendered services. initially filed its claims with the Social Security  The Court highlighted that PHILHEALTH itself had System (SSS) under the Philippine Medical Care issued circulars extending the filing period due to Commission (PMCC) program. the difficulties faced by members in completing the  The enactment of RA 7875 transferred the required documents. administration of the health insurance program to  The Court found it unreasonable to expect CGH to PHILHEALTH. comply with the 60-day rule 100% of the time, given  CGH's claims, amounting to P14,291,568.71, were the volume of patients and the dependency on denied by PHILHEALTH for late filing. members to submit necessary documents.  The Court of Appeals ruled in favor of CGH, ordering  The Court also recognized the exceptions to the PHILHEALTH to pay the claims. doctrine of exhaustion of administrative remedies,  PHILHEALTH then filed a petition for review on particularly when public interest is involved and  when the administrative body is in estoppel. (1926). In that case the Court upheld the president's right  The Court concluded that denying CGH's claims to remove officers who were "units of the executive would undermine the objectives of the National department." The FTC was different, argued Sutherland, Health Insurance Program and discourage health because it was a body created by Congress to perform quasi- care providers from participating in the program. legislative and judicial functions. The Myers precedent, therefore, did not apply in this situation. HUMPHREY'S EX'R v. UNITED STATES(1935) No. 667 Medalla, Jr. vs. Sayo Case Facts of the case G.R. No. L-54554 President Hoover appointed, and the Senate confirmed, Decision Date Humphrey as a commissioner of the Federal Trade Mar 29, 1981 Commission (FTC). In 1933, President Roosevelt asked for Facts: Humphrey's resignation since the latter was a conservative  Dr. Eustaquio M. Medalla, Jr. (petitioner) and Dr. and had jurisdiction over many of Roosevelt's New Deal Honorato G. Mackay (respondent) were involved in policies. When Humphrey refused to resign, Roosevelt fired a dispute. him because of his policy positions. However, the FTC Act  The Mayor of Caloocan City appointed Dr. Mackay as only allowed a president to remove a commissioner for the Hospital Administrator of the Caloocan City "inefficiency, neglect of duty, or malfeasance in office." General Hospital. Since Humphrey died shortly after being dismissed, his  This appointment was made despite a prior decision executor sued to recover Humphrey's lost salary. by the Presidential Executive Assistant and the Question Civil Service Commission (CSC) revoking Mackay's Did section 1 of the Federal Trade Commission Act earlier appointment as Assistant Hospital unconstitutionally interfere with the executive power of Administrator. the President?  The CSC determined that Dr. Medalla, the Chief of Conclusion Clinics, was next-in-rank and equally qualified for The unanimous Court found that the FTC Act was the position. constitutional and that Humphrey's dismissal on policy  Dr. Medalla protested Mackay's appointment, leading grounds was unjustified. The Court reasoned that the the CSC to disapprove Mackay's appointment and Constitution had never given "illimitable power of removal" order the Mayor to appoint Medalla instead. to the president. Justice Sutherland dismissed the  Mackay sought reconsideration but filed a petition government's main line of defense in this case which relied for certiorari, prohibition, and mandamus with heavily on the Court's decision in Myers v. United States preliminary injunction in the Court of First  Instance (CFI) before the reconsideration could be the courts seek to interpret, apply, or implement resolved. the law.  The CFI denied Medalla's motion to dismiss the  The Court cited precedents and legal principles petition, prompting Medalla to seek the Supreme supporting this view. Court's intervention to restrain the CFI from  Regarding the merits of the case, the Court found proceeding with the case for lack of jurisdiction. that the Civil Service Commission and the Issue: Presidential Executive Assistant did not commit 1. Does the Court of First Instance have jurisdiction to grave abuse of discretion. review decisions of the Civil Service Commission  The Revised Charter of the City of Caloocan and the and the Presidential Executive Assistant? Civil Service Decree (PD No. 807) stipulate that the 2. Was there a grave abuse of discretion by the Civil Mayor's power of appointment is subject to Civil Service Commission and the Presidential Executive Service laws, rules, and regulations, including the Assistant in revoking Mackay's appointment and next-in-rank rule. ordering Medalla's appointment?  Dr. Medalla, as the Chief of Clinics, was next-in-rank Ruling: to the Hospital Administrator position, and his 1. The Supreme Court upheld the jurisdiction of the qualifications were at par with those of Dr. Mackay. Court of First Instance to review decisions of the  The prescribed administrative procedure for redress Civil Service Commission and the Presidential was followed by Medalla, and the decisions of the Executive Assistant. Civil Service Commission and the Presidential 2. The Supreme Court found no grave abuse of Executive Assistant were based on a judicious discretion by the Civil Service Commission and the assessment of the qualifications of both contenders. Presidential Executive Assistant in revoking  The Court also noted that while a local executive Mackay's appointment and ordering Medalla's should be allowed to choose men of his confidence, appointment. this choice must be within the bounds of the law and Ratio: regulations.  The Supreme Court ruled that the power of judicial  The revocation of Mackay's appointment was not review by the Court of First Instance over decisions arbitrary and was supported by a careful study of of the Civil Service Commission and the Presidential the qualifications and the organizational structure Executive Assistant is valid. of the hospital.  This is based on the principle that the legality of executive acts is subject to judicial review, not Luzon Development Bank vs. Association of Luzon because the Executive is inferior to the courts, but Development Bank Employees because the law is above the Chief Executive, and Case G.R. No. 120319 2. Whether the decision of the Voluntary Arbitrator Decision Date can be set aside and whether enforcement can be Oct 5, 1995 prohibited. Ruling: Facts: 1. The Voluntary Arbitrator found that Luzon  The case involves Luzon Development Bank (LDB) Development Bank had violated the Collective as the petitioner and the Association of Luzon Bargaining Agreement provision and the Development Bank Employees (ALDBE) along with Memorandum of Agreement on promotion. Atty. Ester S. Garcia, the Voluntary Arbitrator, as 2. The Supreme Court resolved to refer the case to the respondents. Court of Appeals for proper disposition.  The dispute arose from a submission agreement Ratio: between LDB and ALDBE to resolve whether the  Arbitration in labor law involves referring a labor bank had violated the Collective Bargaining dispute to an impartial third party for Agreement (CBA) provision and the Memorandum of determination based on evidence and arguments Agreement dated April 1994 concerning promotions. presented by the parties, who have agreed to accept  The parties agreed to submit their respective the arbitrator's decision as final and binding. Position Papers between December 1-15, 1994.  Arbitration can be either compulsory or voluntary.  ALDBE submitted its Position Paper on January 18, In this case, it was voluntary, based on a clause in 1995. the CBA.  LDB failed to submit its Position Paper despite  The jurisdiction of a voluntary arbitrator is limited reminders from the Voluntary Arbitrator. compared to that of a labor arbiter and the National  On May 24, 1995, the Voluntary Arbitrator rendered Labor Relations Commission (NLRC). a decision without LDB's Position Paper, finding that  The decision of a voluntary arbitrator is final and the bank had not adhered to the CBA provision or executory after ten days from receipt by the parties, the Memorandum of Agreement on promotion. with no express mode of appeal.  LDB filed a petition for certiorari and prohibition to  Historically, decisions of voluntary arbitrators have set aside the decision of the Voluntary Arbitrator been elevated to the Supreme Court on a petition for and to prohibit her from enforcing the same. certiorari, which is illogical and imposes an Issue: unnecessary burden on the Supreme Court. 1. Whether Luzon Development Bank violated the  The Supreme Court held that the decision or award Collective Bargaining Agreement provision and the of a voluntary arbitrator should be appealable to the Memorandum of Agreement dated April 1994 on Court of Appeals, in line with the procedure promotion. outlined in Revised Administrative Circular No. 1-95.   This approach is consistent with legislative intent fishing in San Miguel Bay. and provides a uniform procedure for the appellate  Whether the issuance of these executive orders review of adjudications of all quasi-judicial entities constituted an undue delegation of legislative not expressly excepted from the coverage of Section powers to the President. 9 of B.P. 129.  Whether the lower court erred in requiring the  The Court resolved to refer the case to the Court of Secretary of Agriculture and Natural Resources and Appeals for proper disposition. the Director of Fisheries to post a bond in the action Araneta vs. Gatmaitan against them. Case Ruling: G.R. No. L-8895  The Supreme Court reversed the lower court's Decision Date decision. Apr 29, 1957  Executive Orders Nos. 22, 66, and 80 were declared Facts: valid.  Salvador Araneta (Secretary of Agriculture and  The Court held that the President had the authority Natural Resources) and Deogracias Villadolid to issue these executive orders. (Director of Fisheries) were respondents.  The issuance did not constitute an undue delegation  Petitioners, including Exequiel Soriano, challenged of legislative powers. Executive Orders Nos. 22, 66, and 80.  The requirement for the Secretary and Director to  President Ramon Magsaysay issued these orders in post a bond was deemed moot and academic. 1954 to ban trawl fishing in San Miguel Bay, Ratio: between Camarines Norte and Camarines Sur.  Sections 75 and 83 of the Fisheries Law empowered  Local fishermen and civic organizations complained the Secretary of Agriculture and Natural Resources that trawl fishing was depleting marine resources. to regulate or ban fishing methods that could deplete  Petitioners, who were trawl operators, filed a marine resources. complaint for injunction and/or declaratory relief,  The Secretary operated under the general challenging the validity of the executive orders. supervision and control of the President, thus the  The Court of First Instance of Manila ruled in favor President could exercise the same power through of the petitioners, declaring the executive orders executive orders. invalid and issuing an injunction against their  Section 10(1) of Article VII of the 1935 Philippine enforcement. Constitution grants the President control over Issue: executive departments and mandates the faithful  Whether the President had the authority to issue execution of laws. Executive Orders Nos. 22, 66, and 80 banning trawl   Section 63 of the Revised Administrative Code allowances of the new judges and determine the allows the President to issue executive orders on completion date of the reorganization. matters of general concern.  The Solicitor General defended the law, asserting it  The Fisheries Act was complete in itself and left was a legitimate exercise of legislative power and only the implementation to the Secretary, thus the that allegations of bad faith and threats to judicial President's actions did not constitute an undue independence were unfounded. delegation of legislative power.  The Supreme Court ultimately dismissed the  The Supreme Court emphasized the importance of petition, upholding the constitutionality of Batas protecting marine resources and supported the Pambansa Blg. 129. executive orders as necessary measures for the Issue: welfare of the coastal provinces' inhabitants.  Does Batas Pambansa Blg. 129 violate the security of tenure provision of the Constitution by abolishing existing inferior courts and terminating the incumbency of their judges? De la Llana vs. Alba  Does the law constitute an undue delegation of Case legislative power to the President? G.R. No. 57883 Ruling: Decision Date  The Supreme Court ruled that Batas Pambansa Blg. Mar 11, 1982 129 does not violate the security of tenure provision Facts: of the Constitution.  Petitioners, including Gualberto J. de la Llana, a  The Court also ruled that the law does not constitute presiding judge, and several other judges and an undue delegation of legislative power to the lawyers, challenged the constitutionality of Batas President. Pambansa Blg. 129.  The law, enacted on August 14, 1981, aimed to Ratio: reorganize the judiciary in the Philippines.  The Supreme Court held that the enactment of Batas  Petitioners argued that the law violated the security Pambansa Blg. 129 was a legitimate exercise of of tenure provision of the Constitution by abolishing legislative power to reorganize the judiciary, driven existing inferior courts and terminating the by the urgent need to address inefficiencies and incumbency of their judges unless reappointed. delays in the judicial system.  They also claimed that the law constituted an undue  The Court emphasized that the abolition of the delegation of legislative power to the President, who existing inferior courts and the termination of their was given the authority to fix the compensation and incumbents' positions did not impair the  independence of the judiciary or the security of February 9, 1981. tenure guarantee.  This reorganization led to the abolition of all  Incumbent judges with good performance records existing positions in the LRC, including Garcia's could be reappointed without interruption in their position as Deputy Register of Deeds II. service.  Garcia, a Bachelor of Laws graduate and a first-grade  The Court found that the provision granting the civil service eligible, had held various positions in President the authority to fix the compensation and the LRC since 1977 but was not a member of the allowances of the new judges was not an undue Philippine Bar, a new qualification required for key delegation of legislative power, as clear standards positions in NALTDRA. were provided.  Garcia's temporary appointment as Deputy Register  The reorganization was to be carried out in of Deeds II was terminated on February 9, 1987, due accordance with the President's constitutional duty to her non-compliance with the new qualification to ensure the faithful execution of laws and the and allegations of misconduct. judiciary's commitment to uphold constitutional  The Civil Service Commission later directed her rights. reinstatement, arguing that the new qualification  The Court dismissed the petition, affirming the should not apply to her. constitutionality of Batas Pambansa Blg. 129.  NALTDRA contested this decision, leading to the National Land Titles and Deeds Registration present petition. Administration vs. Civil Service Commission Issue: Case 1. Was the abolition of positions in the Land G.R. No. 84301 Registration Commission (LRC) and the subsequent Decision Date reorganization into the National Land Titles and Apr 6, 1993 Deeds Registration Administration (NALTDRA) Facts: carried out in good faith?  The case involves the National Land Titles and 2. Should the new qualification requirement of Bar Deeds Registration Administration (NALTDRA) and membership for the position of Deputy Register of the Civil Service Commission (CSC) with Violeta L. Deeds II apply to existing employees like Garcia who Garcia as the private respondent. were already in service before the reorganization?  Decided on April 7, 1993, under G.R. No. 84301, with Ruling: Justice Campos, Jr. as the ponente. 1. The Supreme Court ruled that the abolition of  The dispute arose from the reorganization of the positions in the LRC and the reorganization into Land Registration Commission (LRC) into NALTDRA, NALTDRA were carried out in good faith. authorized by Executive Order No. 649, effective 2. The Court decided that the new qualification  requirement of Bar membership for the position of Deputy Register of Deeds II applies to all, including existing employees like Garcia. Ratio:  Executive Order No. 649 explicitly provided for the abolition of all existing positions in the LRC, meaning all positions were deemed non-existent from the moment the implementing order was issued.  This did not constitute removal but rather the abolition of positions, meaning there was no tenure to speak of.  The Court emphasized that the abolition of an office by a legitimate body, if done in good faith, suffers from no infirmity.  The reorganization aimed to improve services and systematize operations, and the requirement of Bar membership for key positions was imposed to meet changing circumstances and new developments.  Garcia, not being a member of the Bar, did not meet this new qualification and thus could not hold any key position in NALTDRA.  The Court rejected the "vested right theory" advanced by the CSC, stating that there is no vested interest or absolute right to hold a public office, except for constitutional offices with special immunity regarding salary and tenure.  Therefore, Garcia could not be reinstated to her former position without violating the express mandate of the law.