Case Digest (G.R. No. 148208)
Facts:
Central Bank (Now Bangko Sentral ng Pilipinas) Employees Association, Inc. v. Bangko Sentral ng Pilipinas and the Executive Secretary, G.R. No. 148208, December 15, 2004, the Supreme Court En Banc, Puno, J., writing for the Court.Petitioner Central Bank (now Bangko Sentral ng Pilipinas) Employees Association, Inc. (petitioner) challenged the last proviso of Section 15(c), Article II of Republic Act No. 7653 (the New Central Bank Act, enacted July 3, 1993), by filing a petition for prohibition on June 8, 2001 against respondents Bangko Sentral ng Pilipinas (BSP) and the Executive Secretary. Petitioner sought to restrain respondents from implementing the proviso on the ground that it violates the constitutional guarantee of equal protection. The petition alleged injury to some 2,994 rank-and-file BSP employees (those in Salary Grade 19 and below). The case reached the Supreme Court by an original petition for prohibition filed directly with this Court.
The challenged text of Section 15(c) authorized the Monetary Board to institute the BSP’s own compensation structure but expressly provided that “compensation and wage structure of employees whose positions fall under salary grade 19 and below shall be in accordance with the rates prescribed under Republic Act No. 6758” (the Salary Standardization Law, SSL). Petitioner’s core claim was that the proviso improperly created two classes within the BSP—officers (exempt, SG 20 and above) and rank-and-file (non‑exempt, SG 19 and below)—and that this classification is arbitrary and not germane to the Act’s purpose, amounting to invidious discrimination in violation of Art. III, Sec. 1 of the 1987 Constitution.
Respondents (BSP and the Executive Secretary, through the Solicitor General) defended the proviso as a lawful legislative classification, arguing it had a rational basis (to make the BSP competitive for senior talent and to preserve its fiscal/administrative autonomy) and should be construed in harmony with other provisions of RA 7653 and RA 6758. The Solicitor General urged deference to Congress and to the Monetary Board’s mandate to establish professionalism and excellence.
During the pendency of the petition the Court took judicial notice of subsequent congressional enactments (1995–2004) amending charters of other government financial institutions (GFIs) that expressly or implicitly exempted all their employees from the SSL: R.A. No. 7907 (LBP, 1995); R.A. No. 8282 (SSS, 1997); R.A. No. 8289 (SBGFC, 1997); R.A. No. 8291 (GSIS, 1997); R.A. No. 8523 (DBP, 1998); ...(Pro-only)
Issues:
- Does the last proviso of Section 15(c), Article II of R.A. No. 7653 violate the constitutional guarantee that “No person shall be denied the equal protection of the laws” (Art. III, Sec. 1, 1987 Constitution), either on its face or by reason of subsequent legislative enactments exempting other GFIs from ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)