Facts:

The case involves Petronilo L. Ruiz as the petitioner-appellee and Germanico A. Carreon and Venusto C. Hamoy as the respondents-appellants. The events leading to the case began when Petronilo L. Ruiz was appointed as the Chief of Police of Dapitan City on March 16, 1966. On August 6, 1968, the Acting City Fiscal of Dapitan filed an information against Ruiz for "other light threats," prompting the City Mayor, Germanico A. Carreon, to issue an order suspending Ruiz effective August 7, 1968. Following this suspension, Carreon appointed Venusto C. Hamoy, a police lieutenant, as the Officer-In-Charge of the police department. In response, Ruiz filed quo warranto proceedings against Carreon and Hamoy, arguing that the Mayor lacked the authority to suspend him and that Hamoy was unlawfully occupying his position. The respondents contended that the Mayor had the power to suspend Ruiz under the provisions of the Police Act. The Court of First Instance of Zamboanga del Norte ...

Facts:

1. Appointment and Assumption of Office:

   • Petitioner Petronilo L. Ruiz was appointed as Chief of Police of Dapitan City by the President of the Philippines on February 17, 1966, and assumed office on March 16, 1966. His appointment was confirmed by the Commission on Appointments under Section 19 of Republic Act No. 3811 (Charter of Dapitan City).

2. Suspension and Criminal Charge:

   • On August 6, 1968, the Acting City Fiscal of Dapitan filed an information charging Ruiz with "other light threats."
   • Respondent Germanico A. Carreon, the City Mayor, issued an order suspending Ruiz effective August 7, 1968.
   • Mayor Carreon designated respondent Venusto C. Hamoy, a police lieutenant, as Officer-In-Charge of the Police Department during Ruiz's suspension.

3. Legal Basis for Suspension:

   • Respondents argued that Mayor Carreon had the authority to suspend Ruiz under the Police Act of 1966 (Republic Act No. 4864).
   • Ruiz filed a quo warranto proceeding, claiming that the Mayor had no authority to suspend him and that Hamoy was usurping his office.

4. Lower Court Decision:

   • The Court of First Instance of Zamboanga del Norte ruled in favor of Ruiz, nullifying the suspension order and declaring him entitled to reinstatement as Chief of Police with all privileges and emoluments.

5. Relevant Laws:

   • Republic Act No. 3811 (Dapitan City Charter) vested the power to appoint and remove the Chief of Police in the President.
   • Republic Act No. 4864 (Police Act of 1966) transferred the power to appoint the Chief of Police to the City Mayor effective January 1, 1968.
   • Republic Act No. 5185 (Decentralization Act of 1967) also vested the power to appoint and remove the Chief of Police in the City Mayor.

6. Police Manual Provision:

   • Section 3 of Rule XIII of the Police Manual, issued on December 30, 1967, stated that chiefs of police appointed by the President could only be suspended or removed by the President.

Issue:

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Ruling:

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Ratio:

1. Presidential Appointment and Tenure:

   • Ruiz was appointed by the President under Republic Act No. 3811, and his tenure was protected by the laws in force at the time of his appointment.
   • The subsequent enactment of Republic Act No. 4864 and Republic Act No. 5185 did not retroactively strip the President of the authority to suspend or remove Ruiz.

2. Police Manual as Official Interpretation:

   • Section 3 of Rule XIII of the Police Manual, issued by the Police Commission, clarified that chiefs of police appointed by the President could only be suspended or removed by the President.
   • This provision was deemed an official interpretation of Republic Act No. 4864 and was entitled to great weight.

3. Protection Against Political Interference:

   • Allowing city mayors to suspend presidential appointees would undermine the independence and integrity of the police force and create opportunities for political interference.
   • The circumstances surrounding the criminal charge against Ruiz suggested that the suspension was politically motivated.

4. General Supervision by the President:

   • The Constitution vests the President with general supervision over local governments, which is inconsistent with the authority of city mayors to suspend presidential appointees.