Case Summary (G.R. No. 166620)
Scope of Presidential Reorganization Authority
Under the 1987 Constitution, the President has control over the executive branch. Section 31 of the Administrative Code grants the President continuing authority to reorganize the Office of the President and agencies attached thereto to achieve simplicity, economy, and efficiency—by abolishing or merging units, transferring functions, and realigning offices. General appropriations laws (e.g., RA 7645, RA 8760 and the 2003 GAA) further authorize the President to scale down, abolish, or reorganize agency activities and realign appropriations accordingly.
EO 378’s Amendments to EO 285 Fall Within Reorganization Power
EO 378 did not abolish the NPO nor transfer its core functions away; it simply removed the blanket exclusivity of NPO’s printing services (except election paraphernalia) and required the NPO to compete with private sector providers under cost and quality conditions. It also limited NPO’s GAA appropriation to its own income. These changes constitute permissible structural and functional adjustments designed to promote efficiency and fiscal responsibility, well within the President’s delegated legislative authority under the Administrative Code and supported by procurement reform policy.
Security of Tenure and Good Faith
Petitioners claimed EO 378 threatened their security of tenure by paving the way for NPO’s abolition. They offered no evidence that positions would be abolished, nor that the order was motivated by bad faith or political considerations. A reorganization effected
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Facts
- Petitioners are employees of the National Printing Office (NPO), created on July 25, 1987 by Executive Order No. 285 issued by President Corazon C. Aquino.
- Section 6 of EO 285 gave the NPO exclusive printing jurisdiction over (a) standard and accountable forms of all levels of government, (b) official ballots, and (c) public documents such as the Official Gazette, General Appropriations Act, and Philippine Reports.
- On October 25, 2004, President Gloria Macapagal Arroyo issued Executive Order No. 378, which amended Section 6 of EO 285 by removing the NPO’s exclusive jurisdiction over printing services (except election paraphernalia) and permitting government agencies to compete for private sector printing services based on quality, cost, and timeliness.
- EO 378 also limited the NPO’s appropriation in the General Appropriations Act to its income, effectively subjecting it to market competition and financial self-reliance.
- Petitioners perceived EO 378 as a threat to their security of tenure and as paving the way for the gradual abolition of the NPO.
Procedural History
- Petitioners filed a petition for certiorari and prohibition with prayer for Temporary Restraining Order and Writ of Preliminary Injunction before the Supreme Court, en banc.
- They characterized the petition as a class suit on behalf of all NPO employees.
- Of the original 67 petitioners, 32 executed affidavits of desistance and one denied his signature, leaving only 20 who actually subscribed to the petition.
- The President of the National Printing Office Workers Association (NAPOWA) filed a manifestation opposing the suit, evidencing divergent interests among the purported class.
Issue on Class Suit
- Whether the petition satisfied the three requisites of a class suit under Section 12, Rule 3 of the Rules of Court: (1) common interest, (2)