Case Digest (G.R. No. 127685) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Blas F. Ople v. Torres, G.R. No. 127685, decided En Banc on July 23, 1998 under the 1987 Constitution, petitioner Senator Blas F. Ople challenged Administrative Order No. 308 (issued December 12, 1996 by President Fidel V. Ramos), entitled “Adoption of a National Computerized Identification Reference System.” AO 308 created an Inter-Agency Coordinating Committee (IACC) chaired by the Executive Secretary and composed of heads of key service agencies (GSIS, SSS, NSO, Department of Health, etc.) with the National Computer Center as secretariat. It directed the use of a Population Reference Number (PRN) and biometrics technology to link agency databases, mandated a tri-media information campaign, and sourced funding from agency budgets. Ople filed an original petition on January 24, 1997 and secured a temporary restraining order on April 8, 1997. He alleged that AO 308 (1) usurped Congress’s exclusive legislative power, (2) usurped Congress’s appropriation power, and (3) impe Case Digest (G.R. No. 127685) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Issuance and Content of A.O. No. 308
- On December 12, 1996, President Fidel V. Ramos issued Administrative Order No. 308 (“Adoption of a National Computerized Identification Reference System”) directing:
- The creation of a decentralized Identification Reference System among key basic‐service and social‐security agencies.
- Establishment of an Inter‐Agency Coordinating Committee (IACC) chaired by the Executive Secretary, with members including the heads of the National Computer Center (NCC), National Statistics Office (NSO), Social Security System (SSS), Government Service Insurance System (GSIS), and other departments.
- Designation of the NCC as secretariat to the IACC.
- Use of the NSO-generated Population Reference Number (PRN) as the common reference number.
- Development of standards for biometrics technology and system linkages.
- A tri-media information campaign, funding from agency budgets, and regular reporting to the President.
- A.O. 308 was published in four newspapers on January 22–23, 1997.
- Petition and Procedural History
- On January 24, 1997, Senator Blas F. Ople filed a petition before the Supreme Court, praying that A.O. 308 be declared void.
- Petitioner’s main contentions were that A.O. 308:
- Usurped Congress’s exclusive power to legislate (establish such a system requires a statute).
- Unconstitutionally appropriated public funds (only Congress may appropriate).
- Violated citizens’ right to privacy by laying groundwork for intrusive data-gathering.
- Respondents (Executive Secretary and agency heads) countered that:
- The petition was not justiciable or ripe (implementing rules not yet issued).
- A.O. 308 was within the President’s executive and administrative powers.
- Funding from agency budgets was permissible.
- The order protected, rather than violated, privacy.
- Interim Relief and Threshold Rulings
- On April 8, 1997, the Court issued a Temporary Restraining Order enjoining implementation of A.O. 308.
- The Court held that petitioner had standing as Senator, taxpayer, and GSIS member, and that the challenge was ripe despite absence of implementing rules, because respondents had already begun implementation steps (e.g., bidding notices).
Issues:
- Whether A.O. No. 308 is an unconstitutional usurpation of Congress’s legislative power by creating a national identification system via administrative order.
- Whether the appropriation mechanism of A.O. 308 violates Congress’s exclusive power to appropriate public funds.
- Whether A.O. 308, on its face, impermissibly infringes the constitutional right to privacy by authorizing broad collection, storage, and linkage of personal and biometric data without adequate safeguards.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)