Case Digest (G.R. No. 26979) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Government of the Philippine Islands v. Springer (50 Phil. 259, 1927), the Philippine Government sued Milton E. Springer, Dalmacio Costas, and Anselmo Hilario, three purportedly elected directors of the National Coal Company. Acts Nos. 2705 (1917) and 2822 (1919) had chartered the company and provided that “the voting power of all such stock owned by the Government of the Philippine Islands shall be vested exclusively in a committee consisting of the Governor-General, the President of the Senate, and the Speaker of the House of Representatives.” The Government, owning over 99% of the shares, sought to test this provision by quo warranto. On November 9, 1926, the Governor-General issued Executive Order No. 37, citing U.S. Army Judge Advocate General and U.S. Acting Attorney-General opinions holding the legislative‐member committee provisions null. He announced he would thereafter cast the sole government vote. The President of the Senate and the Speaker nonetheless met on Dece Case Digest (G.R. No. 26979) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Corporate Charter and Government Stock
- Acts No. 2705 (1917) and 2822 (1919) created the National Coal Company, capitalized at ₱3 million, stock divided into 30,000 shares.
- Charter directed the Governor-General to subscribe for at least 51 percent; the Government ultimately acquired over 99 percent (29,981 of 30,000 shares).
- Section 4, as amended, vested the Government’s voting power “exclusively in a committee consisting of the Governor-General, the President of the Senate, and the Speaker of the House of Representatives.”
- Executive Order No. 37
- November 9, 1926: Gov-Gen promulgated E.O. 37, citing U.S. Army Judge Advocate General and U.S. Acting Attorney-General opinions that voting committees created by local statute were nullities and that their functions were executive.
- E.O. 37 directed that the Governor-General thereafter exercise all duties and powers formerly vested in such committees.
- Stockholders’ Special Meeting and Dual Slates
- December 6, 1926, 2:30 p.m.: President of the Senate and Speaker of the House met as “committee” and resolved to vote Government stock for five nominees (including defendants Springer, Costas, Hilario).
- December 6, 1926, 3 p.m.: At the stockholders’ meeting, Gov-Gen’s representative asserted exclusive voting power and cast a different ballot for five nominees (including Agcaoili, Heath, Lagdameo).
- The chair recognized the Senate President/Speaker ballot as valid; Gov-Gen’s protest was overruled; the five named by the legislative officers were declared elected.
- Quo Warranto Proceeding
- Government filed an original quo warranto action to test the validity of the legislative members’ participation in the committee and to oust defendants from directorships.
- Defendants demurred, admitting the material facts.
Issues:
- Separation of Powers
- Does vesting executive functions in legislative officers violate the Organic Act’s tripartite division of powers?
- Can legislative members sit as “voting committee” members for Government-owned stock?
- Executive Order No. 37
- Was the Governor-General authorized by the Organic Act or local law to annul the committee provision and assume exclusive voting power?
- Election of Directors
- Which slate—legislative officers’ or Governor-General’s—legally elected the directors?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)