Title
Buklod ng Kawaning EIIB vs. Zamora
Case
G.R. No. 142801-802
Decision Date
Jul 10, 2001
EIIB employees challenged the deactivation of their agency under Executive Orders 191 and 223, claiming violation of security of tenure. The Supreme Court upheld the President's authority to reorganize, ruling the deactivation valid for streamlining government operations.
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Case Digest (G.R. No. 142801-802)

Facts:

  1. Establishment of EIIB:
    On June 30, 1987, former President Corazon C. Aquino issued Executive Order No. 127, establishing the Economic Intelligence and Investigation Bureau (EIIB) under the Ministry of Finance. The EIIB was tasked with gathering intelligence, investigating economic crimes, and coordinating anti-smuggling operations.

  2. Primary Responsibility for Anti-Smuggling:
    On March 17, 1989, President Aquino issued Memorandum Order No. 225, designating the EIIB as the primary agency responsible for anti-smuggling operations in land areas and inland waters outside the jurisdiction of the Bureau of Customs.

  3. Deactivation of EIIB:
    On January 7, 2000, President Joseph Estrada issued Executive Order No. 191, deactivating the EIIB. The order cited the overlapping functions of the EIIB with other government agencies and the need to streamline operations.

  4. Creation of Task Force Aduana:
    On January 12, 2000, President Estrada issued Executive Order No. 196, creating the Presidential Anti-Smuggling Task Force "Aduana" to combat large-scale smuggling and other economic crimes.

  5. Separation of EIIB Personnel:
    On March 29, 2000, President Estrada issued Executive Order No. 223, which deemed all EIIB personnel occupying specified positions as separated from service effective April 30, 2000, as part of a bona fide reorganization.

  6. Petitioners' Claims:
    The petitioners, employees of the EIIB, filed a petition for certiorari, prohibition, and mandamus, seeking the nullification of Executive Orders Nos. 191 and 223. They argued that the orders violated their constitutional right to security of tenure, were issued in bad faith, and constituted an unauthorized abolition of the EIIB.

Issue:

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Ruling:

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Ratio:

  1. Presidential Authority to Reorganize:
    The President has the authority to reorganize the executive department, including the power to deactivate or abolish offices, as provided under the Administrative Code of 1987 and other laws. This authority is part of the President's power of control over the executive branch.

  2. Distinction Between Deactivation and Abolition:
    Deactivation means rendering an office inactive or ineffective, while abolition means completely doing away with an office. Both are valid reorganization measures, and the President has the authority to carry out such measures.

  3. Good Faith in Reorganization:
    A reorganization is valid if it is pursued in good faith for the purpose of economy or to make the bureaucracy more efficient. The creation of Task Force Aduana, which utilized existing personnel and resources, demonstrated good faith in the reorganization.

  4. No Violation of Security of Tenure:
    The abolition of an office as part of a valid reorganization does not violate the security of tenure of the incumbents. The positions cease to exist, and the separation of employees is not considered a removal or dismissal.

  5. Economic and Efficiency Considerations:
    The Court recognized the government's need to streamline operations and reduce expenses, especially in light of economic challenges. The deactivation of the EIIB and the creation of Task Force Aduana were aimed at achieving these goals.

Conclusion:

The Supreme Court upheld the validity of Executive Orders Nos. 191 and 223, ruling that the President has the authority to reorganize the executive department, including the deactivation of the EIIB. The reorganization was done in good faith to achieve economy and efficiency, and it did not violate the petitioners' right to security of tenure. The petition was denied.


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