Case Digest (G.R. No. 166620)
Facts:
The case at hand involves a petition for certiorari and prohibition filed by a group of employees from the National Printing Office (NPO) against Eduardo R. Ermita, in his capacity as Executive Secretary, along with the Director General of the Philippine Information Agency and the National Treasurer. The petitioners, led by Atty. Sylvia Banda and 66 others, challenged the constitutionality of Executive Order No. 378, issued by President Gloria Macapagal Arroyo on October 25, 2004. This Executive Order amended Section 6 of Executive Order No. 285, which had established the NPO during the presidency of Corazon C. Aquino on July 25, 1987. The original Executive Order No. 285 granted the NPO exclusive jurisdiction over the printing services for government agencies, including the printing of official ballots and public documents. However, Executive Order No. 378 removed this exclusivity, allowing government agencies to source printing services from the private sector, provided tha...
Case Digest (G.R. No. 166620)
Facts:
Background of the Case:
The case arose from a Petition for Certiorari and Prohibition challenging the constitutionality of Executive Order (EO) No. 378, issued by President Gloria Macapagal-Arroyo on October 25, 2004. The petitioners, employees of the National Printing Office (NPO), filed the petition on their own behalf and on behalf of their co-employees, characterizing it as a class suit.
Creation of the NPO:
The NPO was established on July 25, 1987, under EO No. 285 issued by former President Corazon C. Aquino. EO No. 285 merged the Government Printing Office and relevant printing units of the Philippine Information Agency (PIA) to form the NPO. Section 6 of EO No. 285 granted the NPO exclusive jurisdiction over the printing of standard and accountable government forms, official ballots, and public documents.
Issuance of EO No. 378:
On October 25, 2004, President Arroyo issued EO No. 378, amending Section 6 of EO No. 285. EO No. 378 removed the NPO's exclusive jurisdiction over printing services, allowing government agencies to source printing needs from the private sector through competitive bidding. It also limited the NPO's budget to its income, without additional government financial support.
Petitioners' Claims:
The petitioners argued that:
- President Arroyo lacked the authority to amend or repeal EO No. 285, which they claimed was a legislative enactment issued during President Aquino's legislative powers under the Freedom Constitution.
- EO No. 378 violated their security of tenure, as it could lead to the gradual abolition of the NPO.
Issue:
- Procedural Issue: Does the petition qualify as a valid class suit?
- Substantive Issues:
a. Did President Arroyo have the authority to issue EO No. 378, amending EO No. 285?
b. Does EO No. 378 violate the petitioners' right to security of tenure?
Ruling:
The Supreme Court dismissed the petition.
Procedural Issue: The petition did not qualify as a class suit. The petitioners failed to adequately represent the interests of all NPO employees, as they constituted only a small fraction of the affected employees, and there was evidence of divergent opinions among the employees.
Substantive Issues:
a. Authority to Issue EO No. 378: The Court held that President Arroyo had the authority to issue EO No. 378 under her power to reorganize the executive department, as provided in Section 31 of the Administrative Code of 1987. EO No. 378 was a valid exercise of this power, as it aimed to achieve efficiency and economy in government operations.
b. Security of Tenure: The Court found no evidence that EO No. 378 would lead to the abolition of the NPO or violate the petitioners' security of tenure. The petitioners failed to substantiate their claims of bad faith or political motivations behind the issuance of EO No. 378.
Ratio:
Class Suit Requirements: For a petition to qualify as a class suit, it must meet the following requisites:
a. The subject matter must be of common or general interest to many persons.
b. The parties affected must be so numerous that it is impracticable to bring them all to court.
c. The parties bringing the suit must be sufficiently numerous and representative of the class to protect the interests of all concerned.Presidential Power to Reorganize: The President has the authority to reorganize executive offices and agencies under the Administrative Code of 1987 and other relevant laws. This power includes the ability to modify functions and limit appropriations to achieve efficiency and economy.
Security of Tenure: While employees have a right to security of tenure, this right is not absolute. Reorganizations carried out in good faith for the purpose of economy or efficiency are valid, even if they result in the abolition of positions. Petitioners failed to prove that EO No. 378 was issued in bad faith or would lead to the abolition of their positions.
Conclusion:
The Supreme Court upheld the validity of EO No. 378, ruling that it was a valid exercise of the President's power to reorganize executive offices. The petition was dismissed for failing to qualify as a class suit and for lack of merit on the substantive issues.
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