G.R. No. 195190 - Royale Homes Marketing Corp. vs. Alcantara

Petitioners: Gualberto J. de la Llana (Presiding Judge, City Court of Olongapo) and eight other judicial officers and members of the bar.
Respondents: Manuel Alba (Minister of Budget), Francisco Tantuico (Chairman, Commission on Audit), Ricardo Puno (Minister of Justice).
Prayer: Petition for declaratory relief and/or prohibition seeking to enjoin implementation of Batas Pambansa Blg. 129 (“Judiciary Reorganization Act of 1980”) on grounds it violates constitutional guarantees.

Batas Pambansa Blg. 129 reorganizes all inferior courts (Court of Appeals down to Municipal and Circuit Trial Courts), except Sandiganbayan and Court of Tax Appeals.
Transitory provision (Sec. 44): upon Presidential declaration of completed reorganization, “old courts” are “automatically abolished” and incumbents “cease to hold office.”
Petitioners’ claims:

Violation of security of tenure (Art. X, Sec. 7, 1973 Constitution).
Undue delegation to the President of legislative powers (fixing compensation and setting timeframe).
Arbitrary, in bad faith, and undermining judicial independence.

Solicitor General’s Answer (Aug 1981) and Supplemental Answer (Oct 1981) defending constitutionality as legitimate exercise of legislative power.
Petitioners’ Reply (Oct 1981) and amici curiae memoranda.
Oral hearings (Oct 15, 1981) before the full Court; submission upon receipt of Batasang Pambansa legislative debates.

Executive Orders No. 611 (Aug 7, 1980) and No. 619-A (Sept 5, 1980) created Presidential Committee on Judicial Reorganization.
Committee Report (Oct 17, 1980): detailed need for efficiency, expeditious justice, institutional reform as first major reorganization since 1901.
Drafting of Cabinet Bill No. 42 following report’s guidelines; public hearings (Dec 1980); Committee Report No. 225.
Sponsorship speeches in Batasang Pambansa emphasised decongestion of dockets and improved quality of justice; debates spanned 590 pages.
Enactment: B.P. Blg.129 signed Aug 14, 1981; Sec. 43 directs Supreme Court to submit staffing within 30 days; Sec. 44 provides for “automatic” abolition and transfer of personnel, records, functions, funds.

Whether petitioners have “personal and substantial interest” to invoke judicial review of BP 129.
Whether declaratory relief and/or prohibition is the proper remedy to test a statute’s constitutionality.

Does Sec. 44’s abolition provision violate security of tenure of judges (Art. X, Sec. 7)?
Does the Batasan’s (legislature’s) power to reorganize courts (Art. X, Sec. 1) conflict with the Supreme Court’s power to discipline and dismiss judges?

Was the abolition of existing courts done in good faith or out of arbitrariness?
Is abolition of judicial offices a proper means to achieve legislative objectives of efficiency?

Does authorizing the President to fix compensation “along guidelines” and to declare completion of reorganization constitute undue delegation?
Is the absence of a “definite time-frame limitation” in Sec. 44 fatal to its validity?