Case Summary (G.R. No. 155336)
CHR’s Reclassification Scheme
CHR’s Resolution No. A98-047 (September 4, 1998) created ten new positions, including a Director IV and regional Security Officers and Process Servers. Resolution No. A98-055 (October 19, 1998) upgraded various legal, financial, and administrative positions. Resolution No. A98-062 (November 17, 1998) collapsed vacant posts to generate funding.
Request for DBM Approval and Disapproval
CHR submitted its reclassification proposals for DBM approval. Secretary Diokno denied them, citing:
- Absence of statutory or presidential authority to elevate field units or support divisions to bureau or office level.
- DBM’s exclusive mandate under RA 6758 and Section 78 of RA 8522 GAA to regulate compensation and classification.
- Jurisprudence affirming DBM’s sole power to administer the unified compensation and position classification system.
Civil Service Commission Proceedings
CSC-NCR recommended rejection due to DBM’s disapproval. CHREA petitioned CSC-Central Office to uphold that recommendation. CSC-Central Office denied CHREA’s request in Resolutions dated December 16, 1999 and June 9, 2000, sustaining the validity of CHR’s staffing modifications.
Court of Appeals Decision
In CA-G.R. SP No. 59678, the Court of Appeals affirmed the CSC-Central Office, holding that CHR’s action fell within its fiscal autonomy as a constitutional commission. The CA dismissed CHREA’s petition on November 29, 2001, and denied reconsideration on September 11, 2002.
Issue on Review
Whether the CHR may validly implement upgrading, reclassification, creation, and collapsing of plantilla positions without prior DBM approval under the 1987 Constitution and relevant statutes.
Petitioner’s Standing
CHREA, representing rank-and-file CHR employees, demonstrated sufficient injury from alleged favoritism of higher-level positions and potential depletion of savings affecting employee benefits. Its standing was recognized by the CSC and implicitly by the Court of Appeals.
Salary Standardization Law (RA 6758)
RA 6758 mandates DBM to “establish and administer a unified Compensation and Position Classification System” for all government entities. Its coverage expressly includes Constitutional Commissions and offices irrespective of fiscal autonomy status.
DBM’s Regulatory Authority
DBM’s power to administer compensation is neither purely ministerial nor displaced by internal agency charters. Jurisprudence (Victorina Cruz v. Court of Appeals; Philippine Retirement Authority v. Buñag; Intia v. Commission on Audit) confirms the DBM’s supervisory role to review and ensure agency compensation schemes conform to RA 6758.
Constitutional and Statutory Interpretation
Article IX of the 1987 Constitution designates only the Civil Service Commission, Commission on Elections, and Commission on Audit as Constitutional Commissions entitled to fiscal autonomy. The CHR, although a constitutional creation (Article XIII, Section 18), is not among those listed in Article IX. The expressio unius rule excludes the CHR from that category.
Fiscal Autonomy of the CHR
Fiscal autonomy under the Constitution means freedom to allocate appropriations within legal parameters. The SC has recognized such autonomy only for the Judiciary, CSC, COA, COMELEC, and Office of the Ombudsman. CHR’s admission into the Constitutional Fiscal Autonomy Group does not constitutionally confer autonomy.
Statutory Limitation on Reclassification
RA 8522 itself qualifies any organizational adjustments by requiring that implementation “shall be in accordance with salary rates, allowances and other benefits authorized under compensation standardization laws.” This proviso
Case Syllabus (G.R. No. 155336)
Antecedent Facts
- Republic Act No. 8522 (General Appropriations Act of 1998) included special provisions granting fiscal autonomy to “Constitutional Commissions and Offices enjoying fiscal autonomy,” authorizing them to adjust organizational structures and personnel items within their appropriations, subject to compliance with compensation standardization laws.
- On 4 September 1998, the CHR promulgated Resolution No. A98-047 adopting an upgrading and reclassification scheme for selected positions, creating ten additional plantilla posts from savings under Personnel Services.
- On 19 October 1998, CHR issued Resolution No. A98-055 further upgrading salary grades of various positions and creating/upgrading five security and attorney posts, funded by savings.
- Through Resolution No. A98-062 dated 17 November 1998, CHR “collapsed” several vacant positions (e.g., Attorney III, Attorney IV, Chemist III) to fund the reclassification scheme.
- The CHR forwarded these staffing modifications to the Department of Budget and Management (DBM) for approval, but DBM Secretary Benjamin Diokno denied the request, citing absence of legal basis for elevating divisions to bureaus/offices and the DBM’s sole authority under RA 6758 to administer the unified compensation and position classification system.
- The Civil Service Commission–National Capital Region recommended rejection of the subject appointments due to DBM’s disapproval. CHREA petitioned the CSC-Central Office to affirm that recommendation.
- CSC-Central Office, in Resolutions dated 16 December 1999 and 9 June 2000, denied CHREA’s request and sustained the validity of CHR’s reclassification scheme despite DBM’s disapproval.
- CHREA elevated the matter to the Court of Appeals, which on 29 November 2001 (CA-G.R. SP No. 59678) affirmed the CSC-Central Office resolutions; its motion for reconsideration was denied on 11 September 2002.
- CHREA filed a petition for review with the Supreme Court, contesting the Court of Appeals decision and raising issues of fiscal autonomy and DBM approval.
Issue
- Whether the Commission on Human Rights may va