Case Digest (G.R. No. 192791) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Funa v. Villar (G.R. No. 192791, April 24, 2012), petitioner Dennis A. B. Funa assails the constitutionality of Reynaldo A. Villar’s appointment as Chairman of the Commission on Audit (COA). On February 2, 2001, President Macapagal-Arroyo appointed Guillermo N. Carague as COA Chairman for a seven-year term expiring on February 2, 2008. On February 2, 2004, she likewise appointed Villar as COA Commissioner for a term ending February 2, 2011. Upon Carague’s retirement on February 2, 2008, Villar was designated Acting Chairman (February 4–April 14, 2008) and, on April 18, 2008, formally appointed Chairman with a term stated to end February 2, 2011. Villar’s appointment was confirmed by the Commission on Appointments on June 11, 2008. Evelyn R. San Buenaventura was subsequently appointed Commissioner to serve the unexpired portion of Villar’s original commissioner term. Before resolution, Villar signified on February 22, 2011, his intent to vacate the chairmanship, and was succee Case Digest (G.R. No. 192791) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Initial Composition of the COA
- On February 2, 2001, Guillermo N. Carague was appointed COA Chairman for a fixed seven-year term (to February 2, 2008).
- On February 2, 2004, President Macapagal-Arroyo appointed Reynaldo A. Villar as the third COA Commissioner for seven years (to February 2, 2011).
- Villar’s Acting Chairmanship and Promotion
- Upon Carague’s term expiration, Villar served as Acting Chairman from February 4, 2008 to April 14, 2008.
- On April 18, 2008, Villar was formally appointed COA Chairman (confirmed June 11, 2008) allegedly to serve until February 2, 2011 (end of his commissioner term) but he claimed a fresh seven-year term to 2015.
- Subsequent Appointments
- Evelyn R. San Buenaventura was appointed COA Commissioner on January 5, 2010 to fill the unexpired term of Villar as Commissioner (to February 2, 2011).
- Villar signified his intention to vacate upon naming of his successor; he stepped down in early 2011 when Ma. Gracia Pulido-Tan was appointed COA Chairman by President Aquino.
- Procedural Posture
- Dennis A. B. Funa filed a Petition for Certiorari and Prohibition under Rule 65 questioning the constitutionality of Villar’s chairmanship.
- The Court found the case moot by Villar’s resignation but invoked exceptions to mootness (grave constitutional question, public interest, need for guiding principles, and repetition-yet-evading review).
Issues:
- Justiciability
- Is the petition barred as moot and academic, and did petitioner have standing?
- Are there exceptions permitting the Court to decide despite mootness?
- Substantive Constitutional Question
- Does Section 1(2), Article IX-D of the 1987 Constitution — “appointed … for a term of seven years without reappointment” — prohibit a promotional appointment from Commissioner to Chairman?
- If promotional appointment is permissible, what is the maximum permissible term?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)