Case Digest (G.R. No. 83896)
Facts:
The consolidated petitions, filed by Civil Liberties Union and Anti-Graft League of the Philippines, Inc. with Crispin T. Reyes as co-petitioner, challenged Executive Order No. 284 (promulgated July 25, 1987) which permitted members of the Cabinet, undersecretaries and assistant secretaries to hold up to two additional government positions. The petitions, consolidated by resolution dated August 9, 1988, sought a declaration that EO No. 284 violated Section 13, Article VII of the 1987 Constitution and sought writs and other relief; the Court resolved the consolidated cases on February 22, 1991.
Issues:
- Does Section 13, Article VII admit the broad exceptions in Section 7, par. (2), Article IX-B so as to render Executive Order No. 284 constitutional?
- Do *ex‑officio* posts and positions required by the *primary functions* of a Cabinet official fall outside the prohibition of Section 13, Article VII?
Ruling:
The Court declared Executive Order No. 284 null and void for contravening Section 13, Article VII. The Court ordered certain respondents to relinquish the additional offices held in violation of the Constitution, found petitions against other named respondents moot as they no longer occupied the challenged positions, and held that respondents who acted as de facto officers were entitled to emoluments for services actually rendered.
Ratio:
The Court interpreted the Constitution in light of its history and purpose, concluding that the framers intended a stricter, all‑embracing prohibition for the President, Vice‑President, Cabinet members and their deputies and assistants; the qualifying phrase "unless otherwise provided in this Constitution" in Section 13, Article VII must be limited to exceptions expressly set forth therein. Positions held ex‑officio or as duties required by the primary functions of the office do not constitute "any other office" and are permissible only if held without additional compensation; EO No. 284 impermissibly expanded constitutional exceptions and thus was unconstitutional.
Doctrine:
- Section 13, Article VII imposes a stricter prohibition on the President, Vice‑President, Cabinet members and their deputies or assistants from holding any other office or employment, and its exceptions are limited to those expressly provided in the Constitution.
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