Case Summary (G.R. No. 91636)

Legislative Confirmation of Presidential Appointments

• Confirmation by the Commission on Appointments is mandated only for specific presidential appointees as outlined in Section 16, Article VII of the Constitution.
• This includes officers whose appointments are explicitly vested in the President by the Constitution, such as sectoral representatives to Congress and members of constitutional commissions.
• For other government officers, confirmation is not required unless explicitly provided by law or authorized by the President.

Unconstitutionality of RA 6715's Confirmation Requirement

• The National Labor Relations Commission (NLRC) Chairman and Commissioners fall under the category of officers whose appointments do not require confirmation by the Commission on Appointments.
• RA 6715's requirement for such confirmation is unconstitutional as it attempts to amend the Constitution by imposing additional requirements on appointments that are solely the President's prerogative.
• The Court emphasizes that determining the constitutionality of laws is a judicial function, and the provisions of RA 6715 infringe upon the constitutional mandate.

Legislative Authority vs. Judicial Interpretation

• The legislature cannot expand or alter constitutional provisions after the Supreme Court has interpreted them.
• Legislative definitions or declarations cannot bind the courts, as this would infringe upon the judicial function and disrupt the separation of powers.
• The Court maintains that its interpretations of the Constitution are binding and form part of the legal system.

Historical Context of Confirmation Powers

• The framers of the 1987 Constitution intentionally limited the Commission on Appointments' power to confirm presidential appointments, contrasting with the broader powers under the 1935 Constitution.
• This limitation was designed to prevent abuses of power that had occurred under the previous system.
• Any changes to this framework should be addressed through constitutional amendments rather than legislative action.

Supreme Court's Role in Constitutional Interpretation

• Supreme Court decisions interpreting the Constitution are integral to the legal system and cannot be modified except by the Court itself sitting en banc.
• The Court's interpretations reflect the original legislative intent and have the force of law.
• The Court's function is to ensure that legislative actions align with constitutional provisions.

Conclusion on the Constitutionality of RA 6715

• The primary issue is whether Congress can require confirmation for appointments beyond ...continue reading

Case Syllabus (G.R. No. 91636)

Case Overview

• The case revolves around the interpretation of Section 16, Article VII of the 1987 Constitution, particularly regarding the powers of the President to appoint officials and the requirement of confirmation by the Commission on Appointments (CA).
• Petitioner Peter John D. Calderon challenges the appointments made by President Aquino to the National Labor Relations Commission (NLRC) without obtaining confirmation from the CA, as stipulated under RA 6715.

Legal Background

• Section 16, Article VII of the 1987 Constitution outlines the President’s authority to appoint various government officials and the conditions under which such appointments require confirmation by the CA.
• Previous rulings, notably Sarmiento III vs. Mison and Mary Concepcion Bautista vs. Salonga, established that not all presidential appointments require CA confirmation, specifically those not expressly mentioned in the constitutional text.

Key Constitutional Provisions

• The 1987 Constitution provides that the President can appoint heads of executive departments, ambassadors, and others with the CA's consent, while other appointments may not require such confirmation.
• The framers of the Constitution intended to limit the power of the CA to confirm appointments, leading to a more streamlined executive appointment process.

Legislative Context

• RA 6715, also known as the Herrera-Veloso Law, amended the Labor Code to require CA confirm...continue reading