G.R. No. L-19349 - Serrano vs. The National Science Development Board

The National Science Development Board (NSDB) possesses the authority to revive, continue, or terminate projects initiated by the defunct National Science Board (NSB).
This power is derived from the provisions of Republic Act 2067, which established the NSDB and outlined its functions.
The NSDB is tasked with overseeing scientific, engineering, and technological research, and it has the discretion to assess the necessity of ongoing projects.

Employees and officers engaged in projects terminated by the NSDB do not have a right to salaries and wages for services rendered after the termination.
Many of the employees involved were classified as emergency or temporary workers, which further diminishes their claim to continued employment and compensation.
The NSDB's decision to terminate the Rice Research and Development Project No. 2.10 was valid, and any work performed by employees after the termination was done in defiance of the Board's resolution.

The Rice Research and Development Project No. 2.10 was initiated by the NSB to enhance the rice industry in the Philippines.
Felicisimo Serrano was appointed as the director of this project, overseeing a team of temporary employees.
Following the enactment of the Science Act of 1958, the NSB was dissolved, and the NSDB was established, inheriting ongoing projects, including Project No. 2.10.

The NSDB resolved to discontinue Project No. 2.10 after December 31, 1959, citing that the project had reached a commercial stage and was ready for implementation by the Department of Agriculture Seed Board.
Serrano contested this decision, arguing that the project had not yet fulfilled its objectives and continued to work despite the termination notice.
The NSDB's authority to terminate the project was upheld, as it was within its discretion to assess the relevance and necessity of ongoing projects.

Serrano and his team filed a complaint in the Municipal Court of Manila to recover unpaid salaries and damages for work performed after the termination date.
The municipal court dismissed the complaint for lack of merit, a decision that was upheld by the Court of First Instance of Manila upon appeal.
The courts affirmed the NSDB's authority to terminate the project and the lack of entitlement to compensation for services rendered in defiance of the Board's resolution.

The NSDB is vested with broad discretionary powers to formulate and coordinate scientific policies and programs, including the review of existing projects.
The Board's ability to prioritize projects is essential for effective governance, especially in light of financial constraints.
The decision to terminate unnecessary projects is a necessary exercise of discretion to fulfill the NSDB's mandate.

A note from former President Garcia suggesting the continuation of Serrano's project was deemed to have only persuasive, not binding, authori...continue reading