G.R. No. L-2460 - Suanes vs. Chief Accountant

Petitioner Nicetas A. Suanes filed a petition for mandamus to compel payment of his salary as private secretary to Senator Ramon Diokno, a member of the Senate Electoral Tribunal.
Two conflicting appointments were at issue:

An appointment issued on July 1, 1948 by the Secretary of the Senate (approved by the Senate President) setting the salary at P200 per month.
An appointment issued on August 20, 1948 by the Chairman of the Senate Electoral Tribunal, fixing the compensation at P3,600 per annum (equating roughly to P300 per month).

On July 12, 1948, petitioner took the oath of office as Secretary to Senator Diokno.

On August 27, 1948, petitioner Suanes presented a duly certified voucher for the salary covering the period from July 1 to August 15, 1948, based on the Tribunal’s approved rate.
Respondents, namely the Chief Accountant and the Disbursing Officer of the Senate, refused to honor the voucher, contending that they were bound to pay the salary fixed by the appointment issued by the Senate (P200 per month).

Constitutional and statutory provisions provided for the creation of Electoral Tribunals as independent constitutional organs with exclusive power to adjudicate election contests.

Section 182 of the Election Code expressly grants the Tribunal the power to “make the necessary rules for the effective performance of its constitutional functions.”

Although the funds for the Tribunal (P180,000 as appropriated by Republic Act No. 320) are sourced from the Senate appropriation, such funds are earmarked specifically for the Tribunal’s expenses.
The rules adopted by the Senate Electoral Tribunal vest the Chairman with the power to appoint its subordinate personnel, with the approval of the Tribunal, in accordance with the Civil Service Law.

The appointment by the Senate President, under the ordinary administrative power over Senate employees.
The appointment by the Chairman of the Senate Electoral Tribunal, which purports the Tribunal’s independent administrative authority.

Respondents also argued that because the Tribunal’s expenses are part of the Senate appropriation, administration of such funds and appointments should fall under the Senate President’s control.
Petitioner advanced that both the Constitution and the statutory framework require the Tribunal to be independent not only judicially but also administratively.

Should the appointment issued by the Chairman of the Senate Electoral Tribunal (fixing petitioner’s salary at P3,600 per annum) prevail over the appointment issued by the Senate President (which fixed the salary at P200 per month)?

Does the constitutional mandate that creates the Electoral Tribunal as an independent constitutional organ extend to its administrative and personnel matters?
Is the fact that the Tribunal’s funds are appropriated from the Senate sufficient to subject its internal administration and employee appointments to the control of the Senate President?
Does the petition for mandamus correctly compel the disbursing officers to perform their ministerial duty in view of the Tribunal’s independent appointment power?