Title
Bureau of Customs Employees Association vs. Teves
Case
G.R. No. 181704
Decision Date
Dec 6, 2011
BOCEA challenged R.A. No. 9335, alleging violations of due process, equal protection, security of tenure, and undue delegation. SC upheld the law, citing safeguards, valid classification, and clear standards.
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Case Digest (G.R. No. 181704)

Facts:

Enactment of the Attrition Act (R.A. No. 9335)
On January 25, 2005, Republic Act No. 9335, known as the Attrition Act of 2005, was signed into law by former President Gloria Macapagal-Arroyo. The law aimed to optimize the revenue-generation capabilities of the Bureau of Internal Revenue (BIR) and the Bureau of Customs (BOC) by creating a system of rewards and sanctions. It established a Rewards and Incentives Fund (Fund) and a Revenue Performance Evaluation Board (Board) to oversee the implementation of the law. The Fund was sourced from collections exceeding the revenue targets set by the Development Budget and Coordinating Committee (DBCC).

Implementation and Performance Contracts
In 2008, BOC officials began disseminating Performance Contracts to employees, requiring them to meet specific revenue targets. Failure to meet these targets could result in removal from service. The petitioner, Bureau of Customs Employees Association (BOCEA), representing rank-and-file BOC employees, opposed the contracts, arguing that the targets were unrealistic due to government policies like reduced tariff rates and tax breaks for businesses. BOCEA also alleged that employees were coerced into signing the contracts and that those who refused faced threats of reassignment or termination.

BOCEA’s Petition
BOCEA filed a petition for certiorari and prohibition, challenging the constitutionality of R.A. No. 9335 and its Implementing Rules and Regulations (IRR). BOCEA argued that the law violated its members' rights to due process, equal protection, and security of tenure. It also claimed that the law constituted undue delegation of legislative powers and was a bill of attainder.

Issue:

  1. Whether R.A. No. 9335 and its IRR violate the right to due process of BIR and BOC officials and employees.
  2. Whether R.A. No. 9335 and its IRR violate the right to equal protection of the laws.
  3. Whether R.A. No. 9335 and its IRR violate the right to security of tenure.
  4. Whether R.A. No. 9335 constitutes an undue delegation of legislative powers to the Revenue Performance Evaluation Board.
  5. Whether R.A. No. 9335 is a bill of attainder.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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