Case Digest (G.R. No. 155336) Core Legal Reasoning Model
Facts:
On February 14, 1998, Congress enacted Republic Act No. 8522 (General Appropriations Act of 1998) which, under Article XXXIII, granted “Constitutional Offices enjoying fiscal autonomy,” including the Commission on Human Rights (CHR), authority to formulate and implement their organizational structures and use savings for specified purposes, subject to compensation standardization laws. Relying on these special provisions, CHR Chairperson Aurora P. Navarrete-Reciña and Commissioners Marohomsalic, Contreras, Sibulo, and Coquia promulgated Resolution No. A98-047 (September 4, 1998) upgrading selected positions and creating ten new plantilla items, Resolution No. A98-055 (October 19, 1998) further raising salary grades, and Resolution No. A98-062 (November 17, 1998) collapsing vacant posts to fund the scheme. The CHR sought approval from the Department of Budget and Management (DBM), but Secretary Benjamin Diokno denied the request on the ground that (1) no law authorized elevating
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Case Digest (G.R. No. 155336) Expanded Legal Reasoning Model
Facts:
- Legislative and Organizational Background
- On 14 February 1998, Congress enacted Republic Act No. 8522 (General Appropriations Act of 1998), including special provisions for “Constitutional Offices and Commissions enjoying fiscal autonomy,” authorizing them, within appropriations, to reorganize, fix salaries, create positions, and use savings for defined purposes under compensation standardization laws.
- CHR, invoking these provisions, promulgated three resolutions in 1998:
- A98-047 (4 September 1998) – adopted an upgrading and augmentation scheme creating ten new plantilla positions funded from savings;
- A98-055 (19 October 1998) – raised salary grades of selected positions;
- A98-062 (17 November 1998) – “collapsed” certain vacant positions as additional funding sources.
- Administrative Disapprovals and Civil Service Actions
- The Department of Budget and Management (DBM) denied CHR’s request, ruling: no law directed creation of new offices/positions; compensation changes exceeded functional duties; RA 6758 (Compensation Standardization Law) charged DBM with unified classification.
- CSC-NCR (29 March 1999) recommended rejection of the appointments for lack of DBM approval. The CSC Central Office (16 December 1999) reversed that recommendation, denying CHR Employees’ Association (CHREA) motion for reconsideration (9 June 2000).
- Judicial Proceedings
- CHREA elevated the matter to the Court of Appeals, which dismissed the petition and affirmed the CSC Central Office resolutions.
- SC Decision (25 November 2004) granted CHREA’s petition: reversed CA and CSC, reinstated CSC-NCR ruling, and disallowed CHR Resolutions No. A98-047, A98-055, A98-062 for lacking DBM approval.
- CHR filed a Motion for Reconsideration, assigning errors relating to its alleged fiscal autonomy and the disallowance of its resolutions.
Issues:
- Whether the CHR is constitutionally or statutorily granted fiscal autonomy in the same broad sense as the Judiciary, constitutional commissions, and the Office of the Ombudsman.
- Whether Article XXXIII of RA 8522 (GAA 1998) on fiscal autonomy special provisions specifically covers CHR and permits organizational restructuring and position creation without DBM approval.
- Whether the SC erred in reinstating the CSC-NCR ruling that CHR’s staffing modifications required prior DBM approval.
- Whether the SC erred in disallowing CHR Resolutions A98-047, A98-055, and A98-062 for lack of DBM approval.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)