Case Summary (G.R. No. L-25577)
Applicable Law
The relevant legal provision is Article VII, Section 10(4) of the 1987 Philippine Constitution, which outlines the powers of the President to make appointments during Congressional recess and the conditions under which such appointments may be deemed effective.
Legal Issues Presented
The primary issue raised in this case concerns whether Guevara's ad interim appointment lapsed upon the adjournment of the special session of Congress, which concluded sine die at about midnight on January 22, 1966. The petitioner contended that his appointment remained valid because there was no express disapproval from the Commission on Appointments, which had not been organized during the special session. Additionally, he argued that prior to the adjournment of the regular session, Congress was still in continuous session.
Petitioner's Arguments
Guevara's petition was based on three main points:
- His ad interim appointment was permanent and could only become ineffective through specific constitutional scenarios—namely, disapproval by the Commission on Appointments, or adjournment of the regular session of Congress in 1966.
- There had been no express disapproval from the Commission, as it was not constituted during the special session convened by President Marcos.
- The adjournment of Congress had not effectively occurred due to a suspension of the session by the House slated to resume shortly thereafter.
Respondent's Defense
Inocentes, on the other hand, argued that:
- Guevara's appointment lapsed with the adjournment of the special session of Congress held under Proclamation No. 2 by President Marcos.
- Ad interim appointments are invalid after each term of Congress, suggesting that Guevara’s appointment lapsed as of December 30, 1965.
- Guevara’s appointment was null and void due to violations against public morals and policy, referencing the doctrine established in Rodriguez, Jr. vs. Quirino.
Court's Ruling
The Court held that Guevara’s ad interim appointment had indeed lapsed upon the adjournment of the special session. It reasoned that the language of Article VII, Section 10(4) clearly states that ad interim appointments expire at the next adjournment of Congress, irrespective of the session being regular or special.
Interpretation of Constitutional Provisions
The Court emphasized that the framers of the Constitution intended for ad interim appointments to automatically terminate either through disapproval by the Commission on Appointments or the next adjournment of Congress. It clarified that these two modes of termination are independent of each other.
Legal Continuity of Legislative Sessions
The conclusion drawn by the Court was that the adjournment of the Senate at midnight on January 22 meant Congress adjourned, and therefore, Guevara's appointment ceased to be effective. The notion of continuity in sessions, as argued by the petitioner, was rejected, as the Senate's adjournment means legislative action cannot occur without both Houses in session, and no session could exist post-adjournment.
Excess and Abuse of Power
Furthermore, the Court criticized the numerous ad interi
...continue readingCase Syllabus (G.R. No. L-25577)
Case Citation
- 123 Phil. 200
- G.R. No. L-25577
- Date of Decision: March 16, 1966
Background of the Case
- Onofre P. Guevara (Petitioner) was appointed as Undersecretary of Labor on November 18, 1965, by the former Executive and took the oath of office on November 25, 1965.
- Raoul M. Inocentes (Respondent) was appointed to the same position by the incumbent Executive on January 23, 1966.
- The legality of the respondent's appointment became contested, leading to a quo warranto petition by the petitioner.
Petitioner's Arguments
- The petitioner argued that:
- His ad interim appointment was valid and permanent under Article VII, Section 10(4) of the Constitution, which states that such appointments remain effective until disapproved by the Commission on Appointments or until the next adjournment of Congress.
- No express disapproval was made by the Commission on Appointments since it was not constituted during the special session called by President Marcos.
- The special session had not adjourned, as:
- The House had only suspended its session on January 22, 1966, at 10:55 p.m., resuming on January 24, 1966.
- The Senate adjourned sine die, but such adjournment did not equate to a full adjournment of Congress as a whole.
- The phrase "until the next adjournment of Congress" should not be limited to regular sessions but encompass both regular and special sessions.
Respondent's Defenses
- The respondent contended that:
- The petitioner’s appointment lapsed when Congress adjourned its last special session under Proclamation No. 2 of President Marcos on January 22, 1966.
- An ad interim appointment is i