Title
Antiquera vs. Baluyot
Case
G.R. No. L-3318
Decision Date
May 5, 1952
Municipal Board abolished plaintiff's position, approved retirement under Act No. 4183; Secretary of Interior disapproved, citing unmet requirements. Supreme Court ruled in plaintiff's favor, finding Secretary abused discretion by imposing extra conditions.
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Case Digest (G.R. No. L-3318)

Facts:

  1. Reorganization Plan: The Municipal Board of Manila created a committee to reorganize city departments. The committee recommended the abolition of the position of assistant chief deputy sheriff, held by the plaintiff, Cornelio Antiquera.
  2. Abolition of Position: The position was abolished effective July 1, 1947, and removed from the city's Appropriation Ordinance No. 3072.
  3. Retirement Application: On July 30, 1947, Antiquera applied for retirement with gratuity under Act No. 4183. His application was favorably recommended by the Sheriff, the Commissioner of Civil Service, and the Mayor. The Municipal Board approved the application via Resolution No. 291 on August 25, 1947.
  4. Disapproval by Secretary of the Interior: On September 30, 1948, the Secretary of the Interior disapproved Antiquera's retirement, stating that he failed to meet the requirements of Act No. 4183. The Secretary argued that the abolition of Antiquera's position did not constitute a reorganization, as the office's personnel and budget increased, and a new position was created.
  5. Legal Action: Antiquera filed a complaint seeking a declaration of his right to retirement gratuity under Act No. 4183. The trial court ruled in favor of the defendants, holding that the Secretary's decision was discretionary and not subject to judicial interference.

Issue:

  1. Whether the abolition of Antiquera's position constituted a "reorganization" under Act No. 4183.
  2. Whether the Secretary of the Interior abused his discretion in disapproving Antiquera's retirement application.
  3. Whether the courts can interfere with the discretionary decisions of administrative officials.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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