Case Summary (G.R. No. 207950)
Factual Background and Procedural History
Republic Act No. 7842, enacted on July 25, 1994, established TPDH under the supervision of the DOH. On September 8, 2006, President Gloria Macapagal-Arroyo issued E.O. No. 567, which devolved administration and supervision of TPDH from the DOH to the City of Taguig, pursuant to the Local Government Code and the President's continuing authority to reorganize executive offices. Subsequently, City of Taguig formalized the takeover via Executive Order No. 053, and a Memorandum of Agreement was executed between DOH and the City of Taguig detailing the transition process.
Petitioners, employees assigned to TPDH, opposed E.O. No. 567, submitting objections to the Secretary of Health and the Office of the President, both of which took no action. Petitioners then filed a Petition for Declaratory Relief and an amended Petition for Prohibition and Certiorari before the Regional Trial Court (RTC) of Manila, challenging E.O. No. 567 as unconstitutional and illegal, primarily arguing violation of separation of powers and abuse of discretion.
The RTC denied petitioner’s petitions for temporary restraining orders, deemed withdrawn their petition for preliminary injunction, and, after due proceedings, affirmed the constitutionality of E.O. No. 567. The RTC also declared the Municipal Government of Pateros in default for failure to answer. Petitioners' motion for reconsideration was denied, prompting the filing of this petition for review.
Issues Presented
- Whether the doctrine of exhaustion of administrative remedies applies to petitioners’ case.
- Whether Executive Order No. 567 is constitutional.
The Doctrine of Exhaustion of Administrative Remedies
The Supreme Court clarified that although a party must generally exhaust all available administrative remedies before seeking judicial relief, an exception applies when the issue is purely legal in nature. Since the constitutionality of E.O. No. 567 is a purely legal question, petitioners were justified in directly invoking judicial intervention without exhausting administrative remedies.
Constitutionality of Executive Order No. 567
E.O. No. 567 ordered the devolution of administration and supervision of TPDH from the DOH to the City of Taguig, invoking authority under Section 17 of the Local Government Code and the President's constitutional power to reorganize executive offices.
The petitioners' main constitutional challenges against E.O. No. 567 included:
- Alleged amendment of Section 17(e) of the Local Government Code by extending devolution beyond six months after the Code’s effectivity, which they claimed was a legislative prerogative.
- Conflict with the DOH-issued Implementing Rules and Regulations (IRR) exempting district health offices in the National Capital Region (NCR) from devolution.
- Violation of Republic Act No. 7305 for failure to include provisions securing expenses related to the petitioners’ transfer and reassignment.
Legal Analysis of the Executive Order’s Validity
The Court reiterated the requisites for an administrative issuance such as an executive order to be valid:
- Must be authorized by the legislature.
- Must be issued according to prescribed procedures.
- Must be within the scope of delegated authority.
- Must be reasonable.
1. Authorization by Legislature:
E.O. No. 567 cited Section 17 of the Local Government Code which mandates devolution of basic services, including health services, to local government units (LGUs). The Code explicitly supports decentralization and devolution as state policies to promote local autonomy and efficient service delivery.
2. Compliance with Procedures:
No procedural irregularities in issuing E.O. No. 567 were questioned or proven; hence, the issuance is presumed valid.
3. Scope of Authority:
Petitioners’ argument that Section 17(e) limits devolution to six months post-effectivity of the Code was rebutted by the Court’s interpretation that the six-month period was intended as a prompt period for the initial devolution and not an absolute bar to future devolution. This interpretation aligns with the Constitution’s policy on local autonomy under Section 3, Article X. The statute contains no definitive prohibition of devolution thereafter.
The Court rejected petitioners’ reliance on legislative session transcripts as indicative of intent to absolutely bar post-six-month devolution, construing instead that devolution must be completed within the six months but does not preclude subsequent transfers where appropriate, such as in the case of the TPDH established after this period.
Regarding the alleged conflict with the DOH-issued IRR, the Court clarified that only the Oversight Committee composed of representatives from executive and legislative branches has authority to issue the Implementing Rules and Regulations (IRR) of the Local Government Code. The DOH has no independent authority to promulgate a separate IRR on devolution. Furthermore, the purported DOH IRR only exempts district hospitals in NCR from the “process of devolution as prescribed” but does not prohibit their devolution entirely. Moreover, the President’s authority over executive agencies, including the DOH, supersedes any conflicting departmental issuances.
4. Reasonableness:
The Court found that E.O. No. 567 was reasonable, promoting local government autonomy and enhancing delivery of health services. Effectuating decentralization policies reflects a legitimate government objective and constitutes a valid exercise o
Case Syllabus (G.R. No. 207950)
Facts of the Case
- The Taguig-Pateros District Hospital (TPDH) was established on July 25, 1994, by Republic Act No. 7842 under the supervision of the Department of Health (DOH).
- On September 8, 2006, President Gloria Macapagal-Arroyo issued Executive Order No. 567 (E.O. No. 567), which devolved the administration and supervision of TPDH from the DOH to the City of Taguig.
- E.O. No. 567 was issued pursuant to Republic Act No. 7160 (the Local Government Code of 1991) and the President’s continuing authority over executive departments.
- The City of Taguig formalized the takeover of TPDH operations through Executive Order No. 053 dated October 18, 2006.
- A Memorandum of Agreement (MOA) was entered into on October 23, 2006 between the City of Taguig and the DOH detailing the transition.
- Petitioners, employees assigned to TPDH under the DOH, objected to E.O. No. 567 by submitting a position paper to the DOH Secretary and a letter to the Office of the President, both of which were unacted upon.
- Following the issuance of Executive Order No. 001 on January 3, 2007 by Mayor Tinga to implement E.O. No. 567, petitioners filed a Petition for Declaratory Relief and later an Amended Petition for Prohibition and Certiorari to declare E.O. No. 567 unconstitutional.
- The Regional Trial Court (RTC) of Manila denied the petitioners’ plea for Temporary Restraining Orders and preliminary injunction, proceeded with legal issues as decided on the basis of position papers filed.
- The Municipal Government of Pateros was declared in default for failure to answer the petition.
Issues Presented
- Whether the doctrine of exhaustion of administrative remedies applies to the petition filed by the employees.
- Whether Executive Order No. 567 is constitutional considering the Local Government Code, relevant statutes, and principles of separation of powers.
Doctrine of Exhaustion of Administrative Remedies
- The doctrine requires that all administrative remedies must be exhausted before a court may intervene.
- It allows the administrative officials every opportunity to decide on matters within their jurisdiction.
- However, an exception exists if the issue is purely legal.
- Since the legality of E.O. No. 567 is a pure question of law, exhaustion of administrative remedies was not required before filing the petition.
Constitutionality of Executive Order No. 567
- E.O. No. 567 devolved the Taguig-Pateros District Hospital from DOH to the City of Taguig pursuant to the President’s power under the Local Government Code and her authority to reorganize executive departments.
- The Local Government Code’s Section 17 mandates devolution of basic servi