Case Digest (G.R. No. 93867)
Facts:
The case involves Sixto S. Brillantes, Jr. as the petitioner and Haydee B. Yorac, in her capacity as Acting Chairperson of the Commission on Elections (COMELEC), as the respondent. The events leading to the case unfolded after the President of the Philippines designated Associate Commissioner Haydee B. Yorac as Acting Chairman of the COMELEC, following the appointment of Chairman Hilario B. Davide to lead a fact-finding commission investigating the December 1989 coup d'état attempt. The petitioner, Sixto S. Brillantes, Jr., contested this designation, arguing that it violated the independence of the COMELEC as an independent constitutional body. He pointed out that Article IX-C, Section 1(2) of the 1987 Philippine Constitution explicitly states that no member of the COMELEC should be appointed or designated in a temporary or acting capacity. The qualifications of Haydee B. Yorac were not disputed; however, the petitioner emphasized that the choice of an Acting Chairman sh...
Case Digest (G.R. No. 93867)
Facts:
Background:
The petitioner, Sixto S. Brillantes, Jr., challenged the designation of Associate Commissioner Haydee B. Yorac as Acting Chairman of the Commission on Elections (COMELEC) by the President of the Philippines. This designation was made in place of Chairman Hilario B. Davide, who had been appointed to head a fact-finding commission investigating the December 1989 coup d'état attempt.Petitioner’s Claims:
- The petitioner argued that the President’s designation violated Article IX-C, Section 1(2) of the Constitution, which prohibits the temporary or acting appointment of COMELEC members.
- He cited the case of Nacionalista Party v. Bautista, where the Supreme Court revoked a similar designation as unconstitutional.
- The petitioner contended that the choice of an Acting Chairman should be an internal matter for the COMELEC members to resolve, without Presidential interference.
Respondent’s Position:
The Solicitor General, representing the respondent, argued that the President’s designation was necessary for "administrative expediency" to prevent disruption of COMELEC’s functions.
Issue:
- (Unlock)
Ruling:
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Ratio:
Independence of Constitutional Commissions:
The COMELEC, as an independent constitutional body, is not under the control of the President. Its independence is safeguarded by the Constitution, particularly through the security of tenure of its members.Prohibition on Temporary or Acting Appointments:
Article IX-C, Section 1(2) of the Constitution explicitly prohibits the appointment or designation of COMELEC members in a temporary or acting capacity. The President’s designation violated this provision.Internal Discretion of COMELEC:
The choice of an Acting Chairman is an internal matter that should be resolved by the COMELEC members themselves, without Presidential intervention.Government of Laws, Not of Men:
The lack of a statutory rule does not justify the President’s action. The Constitution must prevail, and any void left by the absence of a rule should be filled by the COMELEC members, not the President.Revocation of Designation:
Following the precedent in Nacionalista Party v. Bautista, the Court annulled the designation as unconstitutional, emphasizing that the President’s goodwill does not override constitutional provisions.