A.M. No. 01-1-04-SC-PHILJA - IN RE: Philippine Judicial Academy

The dispute originated from the Court’s Resolution of February 24, 2004, which was aimed at clarifying and strengthening the organizational structure and administrative set-up of the Philippine Judicial Academy (PHILJA).
Under that resolution, the positions of SC Chief Judicial Staff Officer (Salary Grade [SG] 25) and Supervising Judicial Staff Officer (SG 23) were created for several divisions of the PHILJA, including the Publications Division, External Linkages Division (Research, Publications and Linkages Office), Mediation Education and Management Division (Judicial Reforms Office), Corporate Planning Division, and Administrative Division (Administrative and Finance Office).

On May 5, 2005, the DBM issued a Notice of Organization, Staffing, and Compensation Action (NOSCA) which downgraded the positions:

The SC Chief Judicial Staff Officer was reclassified as an Administrative Officer V with a corresponding reduction from SG 25 to SG 24.
The Supervising Judicial Staff Officer was reclassified as an Administrative Officer IV with a reduction from SG 23 to SG 22.

Subsequently, the Court, following the recommendation of the Office of Administrative Services, reaffirmed the original titles and salary grades in a Resolution dated July 5, 2005.

A Memorandum dated October 10, 2005, addressed to then Chief Justice Hilario G. Davide, Jr., was submitted by PHILJA Chancellor Justice Ameurfina A. Melencio-Herrera. In this memorandum, she requested the issuance of another resolution to retain the original titles and salary grades for the two positions in view of the DBM’s downgrading.
Justice Melencio-Herrera based her request on the Court’s earlier Resolution of November 21, 1995, which had provided for the upgrading of various court personnel positions, arguing that the DBM’s actions undermined the Court’s prior determinations.

Atty. Edna E. DiAo, from the Office of the Chief Attorney, submitted a Report on December 1, 2005, recommending that the Court reiterate its Resolution of July 5, 2005 in order to retain the original position titles and salary grades.
The report stressed that the DBM had no authority to revise the Court’s resolutions and that its role was strictly confined to reviewing compensation plans under the framework of the Salary Standardization Law.

The case raised the issue of whether the DBM’s downgrading of the positions contravened the constitutional provisions on the fiscal autonomy of the Judiciary (Article VIII, Section 3) and the Court’s administrative supervision over its personnel (Article VIII, Section 6).
Relying on case law, notably Bengzon v. Drilon, the Court underscored that any interference in the allocation and utilization of funds for the Judiciary would undermine the constitutional guarantee of independence and separation of powers.

Whether the DBM’s revision of the positions (downgrading of the SC Chief Judicial Staff Officer and Supervising Judicial Staff Officer)

Violated the resolutions previously issued by the Court, specifically those of February 24, 2004, and July 5, 2005.
Infringed upon the constitutional mandate of fiscal autonomy and the administrative supervision of court personnel.

Whether the DBM had the authority to reclassify and downgrade the salary grades of positions that were specifically designed by the Supreme Court to reflect the nature of work and responsibilities of PHILJA personnel.
Whether allowing the DBM to override the Court’s resolutions would jeopardize the separation of powers by encroaching on the Court’s exclusive administrative and fiscal prerogatives.