Case Summary (A.M. No. 88-7-1861-RTC)
Key Dates
- December 12, 1986: Presidential Executive Order No. 856 creates Provincial/City Committees on Justice
- June 1, 1988: Executive Order No. 326 amends EO 856
- June 21, 1988: Governor Farinas issues EO RF6-04 designating Judge Manzano as member of the Ilocos Norte Provincial Committee on Justice
- July 4, 1988: Judge Manzano formally requests Supreme Court authorization to accept the Committee appointment
- October 5, 1988: Supreme Court renders its decision
Applicable Law
- 1987 Constitution, Article VIII, Section 12: “The members of the Supreme Court and other courts established by law shall not be designated to any agency performing quasi-judicial or administrative functions.”
- Executive Orders Nos. 856 (creating the Committees) and 326 (amending supervisory provisions)
Factual Background
Judge Manzano was formally appointed by EO RF6-04 to serve on the Ilocos Norte Provincial Committee on Justice, a body tasked with facilitating speedy disposition of cases involving indigent detainees, recommending revisions to prejudicial laws, and investigating complaints against judicial and law enforcement officers. Before assuming his functions, he sought a Supreme Court resolution (1) authorizing his acceptance, (2) declaring that such membership would not violate judicial independence or constitutional prohibitions, and (3) treating the membership as part of his executive-judge duties.
Constitutional and Legal Issue
Does a trial-court judge violate Article VIII, Section 12 of the 1987 Constitution by serving as a member of a Provincial Committee on Justice that performs administrative functions under the supervision of the Secretary of Justice?
Majority Analysis
- Nature of Committee Functions
- The Provincial Committee on Justice exercises administrative functions: it receives complaints against officials, recommends legal reforms, and reports to the Secretary of Justice. Administrative functions involve regulation, control, and promulgation of rules to carry out legislative policy.
- Constitutional Prohibition
- Article VIII, Section 12 prohibits members of the judiciary from designation to any agency performing quasi-judicial or administrative duties.
- Effect of Membership
- By joining a body that performs administrative functions, a judge would encroach upon executive powers and compromise judicial independence.
- Precedent and Principle
- Reliance on past rulings emphasizes the strict separation of judicial duties from non-judicial functions to preserve impartiality and public respect for the judiciary.
Decision
The Supreme Court, en banc, denied Judge Manzano’s request. It held that membership in the Provincial Committee on Justice constitutes administrative service proscribed by the Constitution and would violate the principle of separation of powers.
Dissenting Opinions
Justice Gutierrez, Jr. (joined by Justices Melencio-Herrera, Fernan, Narvasa, Grino-Aquino)
- Argues that the Committee’s work is purely advisory, not regulatory or quasi-legislative, and does not exercise control over individuals.
- Maintains that judges should participate in study groups addressing justice administration, so lon
Case Syllabus (A.M. No. 88-7-1861-RTC)
Facts
- On 4 July 1988, Judge Rodolfo U. Manzano of RTC Branch 19, Bangui, Ilocos Norte, wrote to Chief Justice Marcelo Fernan (through Court Administrator Leo Medialdea) enclosing copies of Executive Order RF6-04 (June 21, 1988) and his appointment as member of the Ilocos Norte Provincial Committee on Justice.
- The Committee was originally created by Presidential Executive Order No. 856 (12 December 1986) and amended by Executive Order No. 326 (1 June 1988).
- Judge Manzano requested a Supreme Court resolution (1) authorizing him to accept and discharge Committee duties, (2) declaring such membership non-violative of judicial independence or constitutional provisions (Section 12, Article VIII; Section 7(2), Article IX-B), and (3) deeming the role part of his primary functions as Executive Judge.
Procedural Posture
- The Supreme Court En Banc received Judge Manzano’s letter under A.M. No. 88-7-1861-RTC.
- The Court examined the nature and functions of Provincial/City Committees on Justice and the applicable constitutional prohibition against designating judges to bodies performing administrative or quasi-judicial functions.
Legal Issue
- Whether Judge Manzano may be designated a member of the Ilocos Norte Provincial Committee on Justice without violating:
• The Independence of the Judiciary;
• Section 12, Article VIII, 1987 Constitution;
• Section 7 (2), Article IX-B, 1987 Constitution; and
• His duties as Executive Judge.
Statutory and Constitutional Provisions
- Executive Order No. 856 (12 Dec 1986), as amended by EO No. 326 (1 Jun 1988):
• Creates Provincial/City Committees on Justice to expedite detainee cases, reduce jai