Title
Ruiz vs. Carreon
Case
G.R. No. L-29707
Decision Date
Mar 30, 1970
The court affirmed that the City Mayor lacks the authority to suspend or remove a President-appointed Chief of Police, ensuring the protection of presidential appointees' integrity and independence from political influence.
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Case Digest (G.R. No. L-29707)

Facts:

  • Petronilo L. Ruiz was appointed Chief of Police of Dapitan City on March 16, 1966.
  • On August 6, 1968, the Acting City Fiscal filed an information against Ruiz for "other light threats."
  • City Mayor Germanico A. Carreon suspended Ruiz effective August 7, 1968.
  • Carreon appointed Venusto C. Hamoy, a police lieutenant, as Officer-In-Charge of the police department.
  • Ruiz filed quo warranto proceedings against Carreon and Hamoy, claiming the suspension was unauthorized and Hamoy was unlawfully occupying his position.
  • The respondents argued that the Mayor had the authority to suspend Ruiz under the Police Act.
  • The Court of First Instance of Zamboanga del Norte ruled in favor of Ruiz, nullifying the suspension and affirming his right to the office.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the City Mayor did not have the authority to suspend Petronilo L. Ruiz, as his appointment was made by the President and could only be suspended or removed by the President for cause.
  • The Court also ruled that Ven...(Unlock)

Ratio:

  • The Supreme Court's decision was based on the interpretation of relevant laws, particularly Republic Act No. 3811, which outlined the appointment and removal process for city officials, including the Chief of Police.
  • Ruiz's appointment was confirmed by the Commission on Appointments, meaning only the President could suspend or remove him as stipulated by law.
  • Subsequent laws, Republic Act No. 4864 and Republic Act No. 5185, transferred the power to appoint chiefs of police to city mayors but did not retroactively affect ...continue reading

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