Case Summary (G.R. No. 181704)

Petition Overview

• The Bureau of Customs Employees Association (BOCEA) filed a petition for certiorari and prohibition under Rule 65, seeking to declare Republic Act No. 9335 (Attrition Act of 2005) and its Implementing Rules and Regulations (IRR) unconstitutional.
• The petitioners requested a permanent injunction against the implementation of the law, claiming it violated the constitutional rights of BOC employees.

Background of R.A. No. 9335

• R.A. No. 9335 was signed into law on January 25, 2005, to enhance revenue generation by the Bureau of Internal Revenue (BIR) and Bureau of Customs (BOC).
• The law established a Rewards and Incentives Fund to motivate officials and employees to exceed revenue targets, with a Revenue Performance Evaluation Board overseeing the implementation.
• The Fund is sourced from excess collections above the set revenue targets, with specific guidelines for allocation and sanctions for underperformance.

Implementation and Controversy

• The IRR was approved on May 22, 2006, and published on May 30, 2006.
• BOCEA alleged that the law and its IRR were unconstitutional, claiming coercion in signing Performance Contracts and that the revenue targets were unattainable due to government policies.
• The association reported instances of harassment and threats against employees who refused to sign the contracts.

Legal Arguments by BOCEA

• BOCEA contended that R.A. No. 9335 violated due process rights, equal protection under the law, and security of tenure for BOC employees.
• The association argued that the law imposed unreasonable burdens on employees and created arbitrary grounds for dismissal without proper hearings.

Respondents' Defense

• The Office of the Solicitor General (OSG) defended the constitutionality of R.A. No. 9335, asserting that it provided valid grounds for dismissal and complied with due process requirements.
• The OSG maintained that the law was designed to optimize revenue collection and that the rights of employees were protected under civil service laws.

Issues for Resolution

• The Court identified key issues:
  1. Whether R.A. No. 9335 and its IRR violate due process rights.
  2. Whether the law discriminates against BIR and BOC employees.
  3. Whether the law undermines security of tenure.
  4. Whether there is undue delegation of legislative power.
  5. Whether R.A. No. 9335 constitutes a bill of attainder.

Court's Ruling on Delegation of Power

• The Court found no undue delegation of legislative power, affirming that the law provided sufficient standards and guidelines for the Revenue Performance Evaluation Board.
• The law's provisions were deemed complete and aligned with the public interest of optimizing revenue collection.

Equal Protection and Security of Tenure

• The Court ruled that R.A. No. 9335 did not violate the equal protection clause, as it established a valid classification based on the distinct functions of the BIR and BOC.
• The law was found t...continue reading

Case Syllabus (G.R. No. 181704)

Introduction

• The case revolves around a petition for certiorari and prohibition filed by the Bureau of Customs Employees Association (BOCEA) against various high-ranking officials including the Secretary of the Department of Finance and the Commissioners of the Bureau of Customs and the Bureau of Internal Revenue.
• The petition challenges the constitutionality of Republic Act (R.A.) No. 9335, known as the Attrition Act of 2005, and its Implementing Rules and Regulations (IRR), seeking to permanently enjoin its implementation.

Background of the Case

• R.A. No. 9335 was signed into law on January 25, 2005, and took effect on February 11, 2005. Its aim is to optimize the revenue-generation capabilities of the Bureau of Internal Revenue (BIR) and the Bureau of Customs (BOC) through a system of rewards and sanctions.
• The law establishes a Rewards and Incentives Fund sourced from excess collections above revenue targets and mandates the creation of a Revenue Performance Evaluation Board responsible for overseeing the implementation of the law.
• BOCEA contends that the law and its IRR violate the constitutional rights of its members by imposing unreasonable revenue targets and coercive measures.

Facts of the Case

• In 2008, the BOC began distributing Collection District Performance Contracts to lower-ranking officials, mandating them to accept revenue targets and outlining consequences for failing to meet those targets.
• BOCEA claimed that many of its members were coerced into signing the Performance Contracts under threats of reassignment or being placed on floating status.
• Despite repeated attempts to discuss and resolve these issues with BOC officials, BOCEA's concerns were dismissed, leading them to formally request the cessation of the implementation of R.A. No. 9335 and its IRR.

Legal Issues Raised

1. Constitutionality of R.A. No....continue reading