G.R. No. L-19349 - Serrano vs. The National Science Development Board

The National Science Board was created under Republic Act 1606 to promote scientific, engineering, and technological research, invention, and development.
It was tasked with conducting studies and investigations to acquire new knowledge in science, engineering, and technology.

The Board created the Rice Research and Development Project No. 2.10 to improve the rice industry.
Felicisimo Serrano, an employee of the Bureau of Plant Industry, was appointed as the director of this project.
Temporary or emergency employees were also appointed to work under Serrano, with their employment set to end on December 31, 1959.

Republic Act 2067, also known as the Science Act of 1958, abolished the National Science Board and replaced it with the National Science Development Board (NSDB).
The NSDB inherited the projects initiated by the National Science Board, including Project No. 2.10.

On August 13, 1959, the NSDB resolved to discontinue Project No. 2.10 after December 31, 1959, on the grounds that the project had completed its research stage and was ready for commercial implementation by the Department of Agriculture Seed Board.
Serrano was notified of this resolution on August 30, 1959, and his request for reconsideration was denied on November 18, 1959.

Despite the notice, Serrano and his team continued working on the project beyond December 31, 1959, arguing that the NSDB had no authority to terminate the project as its objectives had not been fully achieved.
The NSDB refused to recognize their work after December 31, 1959, leading Serrano and his team to file a lawsuit in the Municipal Court of Manila to recover salaries and wages for work performed after that date, as well as damages.
The Municipal Court dismissed the complaint, and the Court of First Instance of Manila affirmed the dismissal.

Discretionary Powers of the NSDB: The NSDB, as the highest scientific agency in the country, was vested with broad discretionary powers to review, continue, or terminate research projects. The Court emphasized that the NSDB’s authority to terminate projects was necessary to ensure efficient allocation of resources and alignment with national scientific priorities.
No Indefinite Continuation of Projects: The Court rejected the argument that Section 30 of the Science Act of 1958 required the indefinite continuation of projects initiated by the National Science Board. The provision merely ensured the transfer of projects to the NSDB, but it did not preclude the NSDB from terminating projects that were no longer necessary or had achieved their objectives.
Precarious Nature of Employment: The Court noted that Serrano and his team were either temporary or emergency employees with no definite tenure. Their employment could be terminated at will, even without cause, and they could not claim a right to continued employment.
Equity and Clean Hands Doctrine: The Court expressed sympathy for Serrano and his team’s claim for payment but ruled that they could not recover salaries for work performed in defiance of the NSDB’s resolution. The doctrine of “he who comes to equity must come with clean hands” applied, as their actions were in violation of the NSDB’s lawful directive.