Title
Supreme Court
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.

Case Digest (G.R. No. 142801-802)
Expanded Legal Reasoning Model

Facts:

  • Creation and Organization of EIIB
    • On January 30, 1987, Executive Order No. 127 established the Economic Intelligence and Investigation Bureau (EIIB) under the Ministry of Finance, vesting it with intelligence, investigation, coordination, supervision, and prosecution functions related to economic offenses.
    • Through Memorandum Order No. 225 (March 17, 1989), EIIB was designated the primary agency for anti-smuggling operations in all land areas and inland waters outside the sole jurisdiction of the Bureau of Customs.
  • Deactivation and Personnel Separation
    • On January 7, 2000, President Estrada issued Executive Order No. 191 deactivating EIIB and transferring its functions to the Bureau of Customs and the National Bureau of Investigation, citing overlapping functions and need for streamlined operations.
    • Executive Order No. 196 (January 12, 2000) created the Presidential Anti-Smuggling Task Force “Aduana,” detailing its powers, staff composition, and reliance on existing government personnel and resources.
    • On March 29, 2000, Executive Order No. 223 deemed specified EIIB positions abolished effective April 30, 2000, resulting in separation of personnel pursuant to bona fide reorganization.

Issues:

  • Whether Executive Orders Nos. 191 and 223 were issued with grave abuse of discretion or in violation of Section 2(3), Article IX-B (security of tenure) of the Constitution.
  • Whether the President has authority to deactivate or abolish an executive-department bureau and to effect a reorganization that results in office abolition or personnel separation.
  • Whether the reorganization was tainted with bad faith—effectively a hoax to create Task Force Aduana—and violated petitioners’ right to security of tenure.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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