Case Digest (G.R. No. 201044) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In BUREAU OF CUSTOMS EMPLOYEES ASSOCIATION (BOCEA) v. TEVES, the petitioners are rank-and-file employees of the Bureau of Customs (BOC), represented by their national president, Romulo A. Pagulayan. On January 25, 2005, former President Arroyo signed Republic Act No. 9335 (the Attrition Act of 2005), which became effective on February 11, 2005. The law established a Rewards and Incentives Fund sourced from collections in excess of targets set by the Development Budget and Coordinating Committee (DBCC), and created a Revenue Performance Evaluation Board (the Board) to allocate incentives and set removal criteria for BIR and BOC personnel. Its Implementing Rules and Regulations (IRR) were approved by a Joint Congressional Oversight Committee on May 22, 2006, and became effective fifteen days later.In early 2008, BOC officers began issuing Performance Contracts pursuant to Section 25(b) of the IRR and Section 7 of RA 9335, binding employees to meet individual revenue targets or
Case Digest (G.R. No. 201044) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Enactment of RA 9335 and Its IRR
- Republic Act No. 9335 (“Attrition Act of 2005”) was signed on January 25, 2005 and took effect on February 11, 2005. It created:
- A Rewards and Incentives Fund sourced from excess collections of the Bureau of Internal Revenue (BIR) and Bureau of Customs (BOC).
- A Revenue Performance Evaluation Board (“Board”) in each agency to set targets, allocate rewards, evaluate performance, and impose sanctions.
- The Implementing Rules and Regulations (IRR) were approved by a Joint Congressional Oversight Committee on May 22, 2006, published May 30, 2006, and became effective fifteen days later. The IRR detailed:
- Allocation, distribution, and release of funds.
- Criteria for removing employees who fall short of revenue targets by at least 7.5%, procedural requirements, exemptions, and appeal mechanisms.
- BOCEA’s Grievances and Petition
- The Bureau of Customs Employees Association (BOCEA), representing rank-and-file BOC employees, alleged that in early 2008:
- High-ranking BOC officials coerced lower-ranking personnel into signing Performance Contracts accepting individual revenue targets and automatic submission to attrition provisions.
- Non-signers faced threats of reassignment, reshuffling, or floating status; only one district collector refused to sign.
- On March 3, 2008, BOCEA filed a petition for certiorari and prohibition under Rule 65 seeking to declare RA 9335 and its IRR unconstitutional for violating:
- Due process and security of tenure (automatic executory removal, no hearing).
- Equal protection (singling out BIR/BOC employees).
- Separation of powers (undue delegation to the Board).
- Prohibition against bills of attainder (punishment without trial).
- Procedural History and Prior Decision
- BOCEA moved to consolidate its petition with Abakada Guro Party List v. Purisima (G.R. No. 166715, Aug. 14, 2008), but consolidation became impossible after Abakada attained finality on September 17, 2008.
- In Abakada, the Court:
- Declared Section 12 (Joint Congressional Oversight Committee) unconstitutional under separation of powers.
- Upheld the constitutionality of the remaining provisions of RA 9335 and the IRR, presuming them valid despite lack of formal committee approval.
- Both BOCEA and respondents filed memoranda pursuant to the Supreme Court’s February 10, 2009 resolution.
Issues:
- Whether RA 9335 and its IRR violate the right to due process of BIR and BOC employees.
- Whether RA 9335 and its IRR violate the right to equal protection of the laws.
- Whether RA 9335 and its IRR violate the right to security of tenure.
- Whether RA 9335 constitutes an undue delegation of legislative power to the Board.
- Whether RA 9335 is a bill of attainder.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)