Case Digest (G.R. No. L-21551) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 560 Phil. 385 (G.R. No. 169752, September 25, 2007), the Philippine Society for the Prevention of Cruelty to Animals (PSPCA), created in 1905 by Act No. 1285 as a private juridical entity, filed a special civil action for Certiorari and Prohibition under Rule 65 of the Rules of Court, in relation to Section 2 of Rule 64, against the Commission on Audit (COA), its Director Rodulfo J. Ariesga, and audit team members Merle M. Valentin and Susan Guardian. The petition challenged COA Office Order No. 2005-021 dated September 14, 2005, and its implementing letter of September 23, 2005, directing an audit survey and detailed audit of PSPCA’s accounts and operations. PSPCA contended it was a private corporation not subject to COA’s audit authority under Section 2(1), Article IX-B of the 1987 Constitution. COA’s General Counsel issued memoranda on May 6 and July 13, 2004, upholding its jurisdiction over PSPCA. After PSPCA’s request for re-evaluation was denied and initial conferences Case Digest (G.R. No. L-21551) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition and challenged acts
- The Philippine Society for the Prevention of Cruelty to Animals (PSPCA) filed a special civil action for certiorari and prohibition under Rule 65, Rollo 14.
- PSPCA assailed COA Office Order No. 2005-021 (Sept. 14, 2005) and COA letter of Sept. 23, 2005, directing an audit survey of its accounts and operations.
- Origin and charter of PSPCA
- Incorporated by Act No. 1285 (Jan. 19, 1905) as a body politic and corporate to enforce anti-cruelty laws and promote animal welfare.
- Original charter (Secs. 4–5) authorized appointment of agents with police powers to arrest violators and entitled PSPCA to one-half of fines collected.
- Legislative amendments and executive order
- Commonwealth Act No. 148 (Nov. 8, 1936) amended Sec. 4: stripped arrest powers; Sec. 2: abolished PSPCA’s share of fines, directing all fines to municipal funds.
- Executive Order No. 63 (Nov. 12, 1936) vested enforcement of animal-cruelty laws exclusively in government police forces.
- COA audit attempts and PSPCA’s objections
- COA Office Order No. 2003-051 (Nov. 18, 2003) initiated an audit survey; PSPCA demurred, invoking Section 2(1), Article IX-D of the 1987 Constitution claiming private status.
- COA General Counsel issued memoranda (May 6, July 13, 2004) reaffirming PSPCA’s subjection to COA audit jurisdiction.
- COA scheduled an audit survey under Office Order No. 2005-021 and the Sept. 23, 2005 letter; PSPCA filed the present petition.
Issues:
- Whether PSPCA is a government agency or instrumentality subject to COA audit jurisdiction.
- Does PSPCA’s special charter and history confer public-corporation status?
- Did amendments erode PSPCA’s governmental character?
- Ancillary questions:
- Effect of the 1935 and 1987 Constitutions and the Corporation Law on PSPCA’s status.
- Validity of PSPCA’s authority to impose or share in fines under its charter.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)