Facts:

The case involves Antonio J. Villegas, in his official capacity as the Mayor of the City of Manila, as the petitioner against Abelardo Subido, in his official capacity as the Commissioner of Civil Service, and Herminio A. Astorga, in his official capacity as Vice-Mayor and Presiding Officer of the Municipal Board of Manila, as respondents. The events leading to the case began on January 4, 1965, when the Commissioner of Civil Service issued Memorandum Circular No. 1, series of 1965, which stated that Republic Act 2260 (Civil Service Act of 1959) impliedly repealed Republic Act 557, which provided the procedure for the removal and suspension of policemen. The circular ordered all provincial boards, city, and municipal councils to cease investigating administrative charges against policemen and to submit a list of pending police cases to the Commissioner within 30 days. On January 13, 1965, another memorandum was issued, stating that Republic Act 2260 also repealed Section 22 o...

Facts:

1. Memorandum Circulars Issued by the Commissioner of Civil Service:

   • On January 4, 1965, the Commissioner of Civil Service issued Memorandum Circular No. 1, series of 1965, stating that Republic Act 2260 (Civil Service Act of 1959) impliedly repealed Republic Act 557, which provided for the procedure of removal and suspension of policemen. The circular ordered:
     • Provincial boards, city, and municipal councils to cease investigating administrative charges against policemen.
     • Submission of a list of pending police cases to the Commissioner within 30 days.
     • Future investigations of police cases to be conducted only under Republic Act 2260.
   • On January 13, 1965, the Commissioner issued Memorandum Circular No. 3, series of 1965, stating that Republic Act 2260 repealed Section 22 of Republic Act 409 (Revised Charter of the City of Manila) on the suspension and removal of appointive city officers or employees not appointed by the President. The circular ordered:
     • The City Mayor of Manila to cease deciding administrative cases of officers and employees in the competitive service.
     • Submission of a list of pending disciplinary cases to the Commissioner within 30 days.
     • Future investigations to be conducted under Republic Act 2260.

2. Legal Actions Filed by the City Mayor of Manila:

   • The City Mayor of Manila, Antonio J. Villegas, filed two separate actions for prohibition and injunction:
     • L-24012 (filed on January 7, 1965): Relating to cases involving policemen under Republic Act 557.
     • L-24040 (filed on January 15, 1965): Relating to cases of competitive employees in the City of Manila under Section 22 of Republic Act 409.
   • The Vice-Mayor of Manila, as Presiding Officer of the Municipal Board, intended to comply with the Commissioner’s circulars, prompting the Mayor to seek judicial intervention.

3. Preliminary Injunction:

   • The Supreme Court issued a preliminary injunction in both cases on January 18, 1965, halting the implementation of the Commissioner’s circulars pending resolution of the cases.

4. Relevant Laws:

   • Republic Act 409 (Revised Charter of the City of Manila): Section 22 grants the Mayor the power to suspend and remove appointive city officers or employees not appointed by the President, subject to appeal to the Office of the President.
   • Republic Act 557: Provides that charges against policemen shall be investigated by the city or municipal council, with decisions appealable to the Commissioner of Civil Service.
   • Republic Act 2260 (Civil Service Act of 1959): Section 16(i) grants the Commissioner of Civil Service final authority to pass upon the removal, suspension, and separation of permanent officers and employees in the competitive service, except as otherwise provided by law.

Issue:

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Ruling:

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Ratio:

1. No Implied Repeal:

   • Repeal by implication is not favored. If two laws can be reasonably reconciled, the construction will be against such repeal. Republic Act 2260, particularly Section 16(i), is not inconsistent with the powers granted to the City Council under Republic Act 557 or the City Mayor under Section 22 of Republic Act 409.
   • Section 16(i) of Republic Act 2260 does not negate the power of the City Council or the City Mayor to originally decide on the removal, suspension, or separation of employees. Instead, it grants the Commissioner of Civil Service final authority to review such decisions on appeal.

2. Saving Clause in Republic Act 2260:

   • The saving clause in Section 16(i) of Republic Act 2260, "Except as otherwise provided by law," preserves the powers granted by special laws like Republic Act 557 and Section 22 of Republic Act 409. These special laws continue to operate alongside Republic Act 2260, which is a general law.

3. Appellate Authority of the Commissioner:

   • Section 16(i) of Republic Act 2260 confers appellate or reviewing powers on the Commissioner of Civil Service. It does not grant exclusive or original jurisdiction to the Commissioner. The City Mayor and City Council retain their powers to initially decide on disciplinary actions, subject to review by the Commissioner.

4. Precedents Cited:

   • The Court cited Castillo vs. Bayona (106 Phil. 1121) and Pangilinan vs. RCA (121 Phil. 351) to affirm that officials vested with removal powers by law can still exercise such powers, subject to the Commissioner’s final authority on appeal.

5. Policy Considerations:

   • The Court acknowledged the criticisms of Republic Act 557, which rendered policemen susceptible to political influence. However, it emphasized that the law had not been expressly repealed and that its provisions for speedy resolution of cases (e.g., 15-day decision period and 60-day preventive suspension limit) reflected Congress’s intent to ensure prompt disciplinary action.

6. Conclusion:

   • Republic Act 557 and Section 22 of Republic Act 409 remain valid and operative. The Commissioner of Civil Service’s role is limited to reviewing decisions on appeal, not assuming exclusive jurisdiction over disciplinary cases involving policemen and city employees.