Admin Law Review

ATENEO LAW SCHOOL ADMINISTRATIVE LAW
2-D [ATTY. ERENETA]

L.T.J.F. 2
nd
Semester S.Y. 2012-2013
Source: De Leon, Hector. Administrative Law: Text and Cases. (6
th
ed. 2010)
ADMINISTRATIVE LAW REVIEWER

I. POWERS AND FUNCTIONS

Powers of Administrative Agencies

As to Nature:
1. Investigatory
2. Quasi-Legislative
3. Quasi-Judicial

As to Degree of Subjective Choice
1. Discretionary
2. Ministerial

Exercise of Powers and Functions
1. Discretionary
To act officially according to the dictates of one's own judgment
Not controlled by the judgment or conscience of others
2. Ministerial
Performed in response to a duty imposed by law
Mere execution of the law or carrying the law into effect
Examples:
Ascertaining facts and collecting information Ministerial
Weighing pieces of evidence against each other - Discretionary
3. Remedies
Arising out of a ministerial function mandamus
Arising out of a discretionary function elevating the matter en consulta

II. INVESTIGATORY POWERS

1. Definition
Power to inspect, secure or require the disclosure of information, reports records, etc.
To require the production of documents
This power is conferred on ALL administrative agencies

2. How Exercised
Agencies may initiate an investigation:
Upon a complaint
Upon its own initiative
As a mandatory duty

3. Limits of Investigatory Powers
Requiring the production of documents is NOT the same as requiring the attendance of
witnesses and the giving of testimony
General Rule: Administrative agencies have no inherent power to require the
attendance of witnesses
Exceptions:
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
When the enabling statute expressly grants such power
Through a court process, when a statute expressly provides for such application
(eg: court enforcement of a subpoena)

4. Hearing
A hearing is not a necessary part of an investigation
A requirement that there be an investigation carries with it no command that a quasi-
judicial hearing be conducted

5. Contempt
Persons failing to obey orders related to an investigative proceeding may be held in
contempt
But an administrative agency cannot punish a person for contempt absent any
statutory grant since this power is inherently vested with the courts

III. QUASI-LEGISLATIVE POWERS

1. Conditions
a) Statute must be complete in itself setting forth the policy to be implemented
b) Statute must have fixed standards stating the boundaries or limits of the agency's
authority

2. Binding Force and Effect
a) A valid rule or regulation has the force and effect of law
b) General Rule: Administrative rules and regulations have no retroactive effect or
applications
c) Exception: When expressly provided by such rule or regulation or enabling statute
d) Power to make implementing or interpretative rule is legislative in character

3. Limitations of Power
a) Cannot make rules that defeat the purpose of the enabling statute
b) Cannot enlarge, alter, modify or limit the terms of the enabling statute
c) Must be uniform in its application or operation
d) Must be reasonable and not discriminatory

4. Regulations
a) Administrative opinion of what a statute means
b) Interpretative in nature
c) Construction of the enabling statute
d) Have validity in judicial proceedings only to the extent that they are correctly
constructed administrative interpretations of the law are always subject to judicial
determination
e) Resembles judicial adjudication but is still legislative in character
f) Entitled to great weight and respect by the courts but are NOT conclusive in nature
regulations will be ignored if found to be erroneous
g) Contingent Rules and Regulations
When the statute takes effect after the happening of a specified event or term
Discretion as to the execution of the law and NOT a discretion to make the law
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
Determination as to whether the event or term, which initiates the effect of the
statute, is left to the administrative agency

5. Ordinance Power of the President
a) Executive Orders Rules for the implementation or execution of Constitutional or
statutory powers

b) Administrative Orders Rules on the aspects of government operations; made in
pursuance of duties as administrative head

c) Proclamations Declaring a status or condition of public moment or interest; fixing a
date (eg: National Holidays)

d) Memorandum Circulars On matters of internal administration; inter-agency matters

e) General or Special Orders Made in his capacity as commander-in-chief of the Armed
Forced of the Philippines

6. Requisites of Validity of Administrative Rules
a) Must be issued on the authority of law
b) Must not be contrary to law or the Constitution in certain cases, notice and hearing
may be required

7. Grant of Rule-Making Powers
a) By a legislative act (express)
b) By implication of powers granted (implied)
c) Example: Power to fix the minimum wage has the implied power to adopt the rules to
make it effective

8. Requirements of Reasonableness
a) Must bear reasonable relation to the purpose sought to be accomplished
b) Supported by reasonable grounds
c) Free from constitutional infirmities and arbitrariness

9. Penal Rules and Regulations
a) Requisites for validity
1. Enabling statute must itself provide for the imposition of a penalty
2. The statute must fix or define such penalty
3. Violation must be punishable under the enabling law itself the administrative
agency merely executes the punishment imposed
4. Rules must be published
b) What is delegated is NOT the power to define what constitutes a criminal offense but
the power to impose the penalty prescribed by the statute

10. Amendment or Repeal of Rules and Regulations
a) Administrative agencies have the authority to modify or repeal the rules it has
promulgated
b) Discretionary and not subject to judicial approval
c) Substantive Requirements for Validity
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
1. Made in accordance with statutory procedural requirements (notice and hearing in
some cases)
2. No retroactive effect unless authorized by the enabling statute
3. Even if the administrative agency is not bound by res judicata, it cannot repeal its
own previous enactment with retroactive effect
4. Procedural rules are liberally construed
d) Procedural Requirements for Validity
1. Filing of 3 copies of such regulation or rule at the University of the Philippines Law
Center
2. Permanent register shall be kept by the issuing agency
3. Records office of the agency shall carry out the requirements of the Administrative
Code
4. The rule or regulation shall become effective 15 days from the date of filing unless
otherwise provided or when emergency situations require and earlier date
5. For rules with penal sanctions must be published in full text
6. In fixing of rates no rule shall be valid unless the proposed rates have been
published for 2 weeks, at least before the implementation thereof

11. Requirements of Notice and Hearing and/or Publication
a) When fixing of rates apply to all enterprises in general (eg: fixing of maximum tuition
fees for private schools)
Legislative in nature
No need for notice and hearing
b) When rate fixing applies to specifically named persons
Quasi-judicial in nature requires notice and hearing
Publication is required as a condition precedent
c) When rules are merely internal AND interpretative in nature
Acts of regulating the agency and NOT the public
Publication is not required

IV. QUASI-JUDICIAL POWERS

1. Adjudicatory Function
a) Primarily regulatory
b) Powers incidental to the administrative duty
c) Extent of powers and jurisdiction largely depends on enabling statute
d) Grant of power or function must be in the law itself

2. Nature of Particular Acts
a) Licensing, Enabling, Approving
1. Discretionary
2. Not quasi-judicial when there are no conflicting claims involved
b) Fixing of rates and charges
1. Application to a general class of people or situations
Quasi-legislative action
No need for prior notice and hearing
2. Application to a specific case or person
Quasi-judicial act
A need for notice and hearing
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
c) Requirements for valid rates
1. Not confiscatory in nature
2. Within the requirements of the enabling statute
3. Reasonable
4. Not unjust

3. Classifications of Adjudicatory Powers
a) Enabling powers granting or revocation of a permit or authorization
b) Directing powers eg: corrective powers of BIR assessors and public utility
c) Dispensing powers:
Authority to relax a prohibition or exempt a subject (person or agency) from an
affirmative duty
Sanctions (forgives) a deviation from a standard
d) Summary powers power to apply compulsion or force to effectuate a legal purpose
without a judicial warrant (eg: abatement of nuisance)
e) Equitable powers power to make application of rules of equity (eg: issue injunctions)

4. Delegation to Administrative Agencies
a) Legislative Powers
1. Legislature must declare a policy and fix a standard
2. Completeness Test:
Subject, matter and extent of operation are stated
Enables one to know his rights and obligations
b) Detailed Standards when not required
1. Necessities of modern legislation dealing with complex economic and social
problems
2. Regulatory enactments under police power
c) If personal judgment is unrestrained (in the opinion) it is not a standard

5. Limitations on Quasi-Judicial Powers
a) An administrative agency may not perform functions which are judicial in nature (eg:
awarding of damages)
b) Exceptions to the rule requiring a standard (uncontrolled discretion) in such cases,
the standard of reasonableness will be applied
1. Handling State funds and property
2. Purely administrative (internal) in nature
3. Recommendations (which are not binding)
4. If it is impractical to law down a comprehensive rule
5. Exercise of police power
6. Nature of privileges (use of property, engaging in occupations and acts)
7. Situations where the State is supreme and has no relation to personal and property
rights

V. CASE DIGESTS AND DOCTRINES

Bagatsing v. COP
Facts:
There is the sale of Petron shares for the government's privatization program. Petitioners
state that the sale contravenes the governments policy that only non-performing assets should be
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
disposed of. But Proclamation 50 classifies 2 types of government assets for privatization: 1. Non-
performing assets and 2. GOCC not necessary to maintain.

Issue: Whether the privatization of Petron violated the proclamation or not

Held:
Such privatization was made in accordance with the proclamation. Such approval by the
COP cannot be reviewed by the Court since it is exclusively an executive function.

Doctrine: The State has uncontrolled discretion in handling its properties and assets as long as
private rights, properties and interests are not affected.

Beja v. CA
Facts:
Rogelio A. Dayan, the PPA General Manager filed an Administrative Case against petitioner
Beja and Hernando G. Villaluz for grave dishonesty, grave misconduct, willful violation of
reasonable office rules. The PPA general manager indorsed it to the AAB (Administrative Action
Board) for "appropriate action." Beja filed with the AAB a manifestation and motion to suspend
the hearing, which the AAB denied.

Issue:
1. Can the PPA general manager issue a preventive suspension order against petitioner?
2. Whether or not it is within the jurisdiction of the AAB to initiate and hear administrative
cases against PPA personnel below the rank of Assistant General Manager?

Held:
1. Yes. Even if the proper disciplining authority is the PPA board of directors, a preventive
suspension is not a penalty thus it can be exercised by the general manager
2. The PPA is an agency attached to the DOTC, which has a larger measure of independence
in terms of supervision and control from the Department to which it is attached. The
department head or secretary concerned may only entertain matters or decisions by the
PPA elevated to him. The transmittal of the complaint by the PPA General Manager to the
AAB was premature.

Doctrine: Attached agencies, having a greater degree of independence from the principal agency,
has the quasi-judicial power to initiate and hear administrative cases against its personnel.

Carmelo v. Ramos
Facts:
The Mayor of Manila issued an executive order creating a committee to investigate the
anomalies involving the license inspectors and other personnel. The committee issued a subpoena
to respondent, a private citizen, requiring him to appear before it in connection with an
administrative case against another person. Respondent refused to appear causing petitioner to
file in the CFI a petition to declare respondent in contempt.

Issue:
Does the committee have the power to subpoena a witness and ask for their punishment for
refusal to comply?

2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
Held:
None. Before one can apply to the courts for the punishment of a hostile witness, he must
first show that he has authority to take testimony or evidence. The delegated power to investigate
does not imply a delegation of the power to take evidence or testimony. The power to take
evidence becomes implied or a necessary exercise of the investigatory powers when there is a
statutory grant of such powers. There is none in this case and to be sure, there is nothing said in
the executive order of the Mayor creating the committee about such a grant of power. All that the
order gives to this body is the power to investigate anomalies involving certain city employees.
Even granting that the mayor has the implied power to require the appearance of witnesses before
him, he cannot delegate this power to a body like the petitioner's committee.

Doctrine: Administrative agencies have no inherent power to require the attendance of witnesses
before them nor to require them to testify unless a statute confers such power upon them.

CIR v. Benguet
Facts:
An executive order imposed VAT rates of either 10% or 0% (zero-rated) to any person who
imports goods depending on the classification of the transaction. Respondent applied for and was
granted by the BIR zero-rated status on its sale of gold to Central Bank. In 1988, the CIR ruled
that the sale of gold to Central Bank is considered as export sale subject to zero-rate. Petitioner
then filed for tax credits after its sale pursuant to the 1988 ruling. The application was denied
pursuant to a 1992 BIR ruling which classified the sale of gold to the Central Bank as non-export
sales thus subject to 10% VAT. The 1992 ruling revoked the 1988 ruling and was applied
retroactively.

Issue: Can the 1992 BIR Ruling be applied retroactively and is the ruling itself valid?

Held:
No. The ruling in question is invalid. Respondent should not be faulted for relying on the
BIR's interpretation of the said laws. Even if the government is not estopped from collecting taxes
this principle must give way to exceptions based on and in keeping with the interest of justice and
fair play.

Corona v CA
Facts:
2 PPA police officers filed in the AAB a complaint for dishonesty against private respondent,
the district manager of the Port of Manila. Private respondent filed a motion to dismiss assailing
the jurisdictional competence of the AAB on the ground that it was the General Manager of the
PPA who had jurisdiction over the case. AAB denied the motion to dismiss. Respondent filed a
petition for certiorari with prayer for preliminary injunction challenging the jurisdiction of the AAB
over the administrative cases against him. The trial court granted said petition.

Issue: Whether or not the Secretary of the DOTC and/or the AAB have jurisdiction to initiate and
hear administrative cases against PPA personnel.

Held:
The Court denied the petition and cited the Beja case. The DOTC secretary's jurisdiction
over disciplinary matters, according to the PPA charter is only appellate in nature. He does not
have the power to initiate the proceedings against a subordinate official of the PPA. The DOTC
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
may not "act directly whenever a specific function is entrusted by law or regulation to a
subordinate.

Cruz v. Youngberg
Facts:
The petitioner attacked the constitutionality of Act No. 3155, which at present prohibits the
importation of cattle from foreign countries into the Philippines. The statute was enacted for the
sole purpose of preventing the introduction of cattle diseases. It grants to the Governor-General,
at his discretion, the authority to lift the prohibition if the decease among foreign cattle has
ceased to be a menace.

Issue: Whether or not there is undue delegation of legislative powers on the Governor-General.

Held:
There is none. The law only confers authority or discretion as to its execution, to be
exercised under and in pursuance of its objectives. The promotion of industries affecting the public
welfare and the development of the resources of the country are objects within the scope of the
police power.

Dela Cruz v. COA
Facts:
The COA issued Memorandum No. 97-038 directing all unit heads/auditors/team leaders
which have effected payment of any form of additional compensation to cabinet secretaries, in
violation of the rule on multiple positions, to immediately cause the disallowance of such
additional compensation. The NHA auditor issued a notice of disallowance pursuant to the COA
memorandum. Petitioners, who are members of the NHA board of directors, contend that the
disallownace is not applicable to them since:
The constitutional ban against dual or multiple positions applies only to the members of
the Cabinet, their deputies or assistants. It does not cover other appointive officials.
NHA directors are not secretaries

Issue: Whether or not there is grave abuse of discretion on the part of COA in issuing such order?

Held:
There is none. The statute creating the NHA mandates that executive secretaries will form
ex-oficio memebrs of the NHA board. Since the secretaries hold such positions in an ex-oficio
capacity, they are not considered to be holding multiple offices since it is merely an imposition of
additional duties as executive secretaries. Since the Executive Department Secretaries, as ex-
oficio members of the NHA Board, are prohibited from receiving "extra (additional) compensation"
it follows that petitioners who sit as their alternates (agents) cannot likewise be entitled to receive
such compensation.

Dimatulac v. Villon
Facts:
This case involves the murder of SPO3 Dimatulac, a relative of the petitioner. A complaint
was filed against Mayor Yabut, the suspect. Upon investigation, the prosecutor recommended that
the lesser crime of homicide be filed against the suspects. Before the Information for homicide
was filed, petitioners appealed the prosecutor's resolution to the Secretary of the Department of
Justice. While the appeal was still pending with the DOJ, the trial court proceeded with the
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
arraignment. The DOJ secretary initailly issued a resolution holding that murder was committed
and ordered the amendment of the Information. However, the order was reversed on the ground
that it was rendered moot and academic by the arraignment.

Issue:
Whether or not the RTC could proceed with the arraignment despite the pending review of
the case by respondent Secretary of Justice.

Held:
It is undebatable that petitioners had the right to appeal to the DOJ from the resolution
(recommendation) of the prosecutor. It is an invocation of the Secretary's power of control over
prosecutors. The Secretary of Justice is only enjoined to refrain, as far as practicable, from
entertaining a petition for review or appeal from the action of the prosecutor once a complaint or
information is filed in court. There was on the part of the public prosecution, indecent haste in the
filing of the information for homicide, depriving the State and the offended parties of due process.
It was grave error for the DOJ to reconsider its resolution and order solely on the basis of the
information that the YABUTs had already been arraigned. In so doing, the DOJ relinquished its
power of control and supervision over the Provincial Prosecutor and the Assistant Provincial
Prosecutors. The Court granted the petition.

Evangelista v. Jarencio
Facts:
Petitioner is the head of an agency vested with all the powers of an investigating
committee including the power to summon witnesses, administer oaths and take testimony or
evidence. The agency was created through an Executive Order by the President. Respondent was
issued a subpoena commanding him to appear to testify in a certain investigation of the agency.
Respondent challenged the legality of the subpoena.

Issue: Whether or not the agency is authorized to issue subpoenas in its conduct of fact finding
investigations.

Held:
Yes. Administrative agencies may enforce subpoenas issued in the course of investigations,
whether or not adjudication is involved and whether or not probable cause is shown. It is enough
that the investigation be for a lawfully authorized purpose. When investigative and accusatory
duties are delegated by statute (in this case the Executive Order) to an administrative body, it too
may take steps to inform itself as to whether there is probable violation of the law. The subpoena
meets the requirements if the inquiry is: (a) within the authority of the agency; (b) the demand is
not too indefinite; and (c) the information is reasonably relevant.

Fortich v. Corona
Facts:
The Office of the President issued a 1997 resolution which substantially modified it's 1996
decision. Said decision had long been final and executory after DAR filed its motion for
reconsideration beyond the reglementary period.

Issue: Was the subsequent modification a void or a valid exercise by the President of his
prerogatives?

2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
Held:
The failure to file a motion for reconsideration is not excusable. While the Court has
allowed a relaxation of procedural rules, it was never meant to forge a bastion for erring litigants
to violate the rules. To warrant the relaxation of the rules, there must be justifiable reasons for it.
Absent any justifiable reasons, the earlier OP decision can no longer be disturbed.

Doctrine: Relaxation of procedural rules is warranted only if there are justifiable reasons to do so.

Hilado v. CIR
Facts:
Petitioner filed his income tax return and claimed an amount as a deductible pursuant to a
circular by the Secretary of Finance. Petitioner's claim was disallowed since the Secretary's
successor subsequently issued a new circular, which revoked the earlier one. The revocation was
due to an erroneous interpretation of a tax statute by the previous Secretary.

Issue: Was the revocation valid and within the authority of the secretary?

Held:
Yes. Construction of a statute by those administering it is not binding on their successors if
the latter believes that a different construction should be given. The circular, having been issued
on a wrong construction of the law cannot give rise to a vested right to the petitioner.

Miller v. Mardo
Facts:
Re-organization plan 20-A gave jurisdiction to the DOLE regional offices over cases of
unclaimed wages, overtime and separation pay. Before the effectivity of the plan, DOLE had no
power to settle such cases.

Issue: Is Plan 20-A invalid as it confers judicial powers to the Regional Offices?

Held:
Yes. What the enabling statute contemplates is merely administrative functions and not
judicial functions. Legislature may confer quasi-judicial functions but even such prerogatives must
be limited to only those incidental to their administrative functions. Just because the statute
granted the power to reorganize the administrative agencies, it does not grant the creation or
delegation of quasi-judicial functions to the agencies, absent a clear or implied authority to do so.

Doctrine: Quasi-judicial functions cannot be implied from a mere grant of power to create
functions in connection with the reorganization of the executive branch.

Olsen v. Rafferty
Facts:
Under the tariff law, certain products from the Philippines were admitted to the United
States duty-free. The Governor-General issued an Executive Order requiring the adoption of rules
by the Collector of Customs and Internal Revenue to insure that the US government will not be
defrauded by an exporter who may introduce products to the US free of duty, but are not products
of the Philippines. The agencies have the duty to ascertain whether exported articles from the
Philippines qualify under the tariff law to be free of duty. Petitioner brought an action for
mandamus to secure an order directing respondents to issue a certificate of origin of cigars for
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
export to the US.

Issue: Does the Executive Order confer a legal right on which an action in court may be
predicated? Can the courts compel the agencies to perform their duties as stated in the Executive
Order?

Held:
No. The order is nothing more or less than a command from a superior to an inferior. The
custom of issuing certificates of origin is based on no statute. Disobedience from such an order
can be punished only by the power which issued it. The presentation of certificates of origin is not
based on a right conferred by the Tariff Act but is simply a method by which such proof can be
made. Since it is not based on a right, the enforcement of the order is beyond the power of the
courts.

Rubi v. Mindoro
Facts:
Petitioner and his companions are being held on a reservation against their will. Legislature
has conferred authority upon the Province of Mindoro do exercise such function.

Issue: Is there unlawful delegation of legislative power?

Held:
No. Discretion may be delegated on matters involving questions of fact. In this case, it is
the interest of law and order. Legislature merely conferred discretionary authority as to the
execution of the law. Who but the provincial governor and the board are better qualified to judge
when such course is deemed necessary.

Buklod ng Kawaning EIIB v. Zamora
Facts:
The Economic Intelligence and Investigation Bureau (EIIB) was created by former President
Corazon Aquino to receive, gather and evaluate intelligence reports and information of illegal
activities affecting the national economy. The function of the EIIB was to conduct anti-smuggling
operations in areas outside the jurisdiction of the Bureau of Customs. 11 years later, President
Estrada issued EO 191 which deactivated the EIIB since its functions overlap with those of the
Bureau of Customs and NBI. President Estrada then issued EO 196 which created the Presidential
Anti-Smuggling Task Force Aduana. Finally, EO 223 was issued which separated from service all
personnel of the EIIB. The petitioners are challenging the authority of the President to abolish the
EIIB.

Issues:
Does the EO 223 violate the security of tenure of EIIB personnel?
Is the reorganization or abolition done in bad faith?
Is the abolition a usurpation of the power of Congress to decide whether or not to
abolish EIIB?

Held:
1. No. EO 223 did not violate the security of tenure of EIIB personnel. There is no such thing as
an absolute right to hold an office. As a general rule, a reorganization is carried out in good faith
if it is for the purpose of economy or to make bureaucracy more efficient. Security of tenure will
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
not prevent the abolition done in good faith.

2. The reorganization was done in good faith since it was aimed to achieve economy and simplicity
in the bureaucracy. Task Force Aduana is to be comprised of people who are already in public
service and employees of existing agencies. It encourages the utilization of personnel and
resources of the already existing departments. The task force was intended to lessen the
expenses of the EIIB.
3. There exists a distinction between the words deactivate and abolish. To deactivate means
to render inactive or ineffective or to break up by discharging or reassigning personnel. In
deactivation, the office continues to exist but it remains dormant. On the other hand, to abolish
means to do away with, to annul, abrogate or destroy completely. Be that as it may, deactivation
and abolition are both reorganization measures. The general rule has always been that the power
to abolish a public office is lodged with the legislature. The exception, however, is that as far as
bureaus, agencies or offices in the executive department are concerned, the Presidents power of
control may justify him to inactivate the functions of a particular office, or certain laws may grant
him the broad authority to carry out reorganization measures. These laws are PD 1772 and RA
8760 which authorizes the President to reorganize the National Government to improve
productivity and efficiency of its operations.
Gaminde v. COA
Facts:
Thelma Gaminde was appointed as Commissioner of Civil Service Commission in 1993. Her
term was to expire on February 1999. She sought clarification from the Office of the President as
to her term and the latter opined that petitioners term of office would expire on February 02,
2000, not on February 02, 1999. On February 04, 1999, Corazon Alma G. de Leon, Chairman of
the CSC, wrote the Commission on Audit requesting opinion on whether or not Gaminde may be
paid her salary notwithstanding the expiration of her appointment on February 02, 1999. The COA
issued an opinion that indeed petitioners term has expired. The CSC resident auditor disallowed
the salaries pertaining to petitioner and her co-terminus staff.

Issue: Whether or not Gamindes term expired on February 1999 as stated in her appointment
paper or on February 2000 as claimed by her.

Held:
Term of an office must be distinguished from tenure of the incumbent. Term means the
time during which an officer may claim an office as a right and fixes the interval of succession.
Tenure represents the term during which the incumbent actually holds the office. Term of office is
not affected by the hold-over of the incumbent after expiration of the term.

The term of the appointed commissioner begins and ends pursuant to the terms provided for
by the Constitution. However, the tenure is counted from the moment the appointed official
actually assumes office. Until a successor is nominated and assumes office, the incumbent holds
the office for a period not exceeding 7 years (same duration as the term). An incumbents tenure
may overlap his term. He may hold an office beyond the 7-year term when a successor has not
yet been appointed provided that his 7-year tenure is not yet over. Since he has exceeded his
lawful term (but not his tenure), he now becomes a de facto officer.

In the case of Gaminde, her term is supposed to end on February 1999 but her 7-year tenure
is to end on February 2, 2000 since she assumed office on June 11, 1993. She served as de facto
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
officer in good faith until February 02, 2000, and thus entitled to receive her salary and other
emoluments for actual service rendered. Consequently, the Commission on Audit erred in
disallowing in audit such salary and other emoluments, including that of her co-terminous staff.

Lacson v. Roque
Facts:
The deputy chief of police was acquitted in a criminal prosecution case instituted at the
instance of Mayor Lacson. He criticized the court, specifically Judge Montesa (the trial judge) for
being incompetent. Judge Montesa responded by filing a libel case against the mayor. The
President wrote to the mayor stating: In view of the pendency of the case against you, for libel,
and pursuant to the present policy of the administration, requiring the suspension of any local
elective official which is being charged before the courts with any offense involving moral
turpitude, you are hereby suspended from office.
Issue: Was the suspension order legal?
Held:
No. The Charter of the City of Manila is silent regarding the suspension or removal of the
mayor. But the Revised Administrative Code does confer upon the President the power to remove
any person from any position of trust or authority under the Government of the Philippines for
disloyalty to the Republic of the Philippines. Even so, these members of the Court opine that the
alleged offense for which Mayor Lacson has been suspended is not one of the grounds just
enumerated, and are in complete agreement with the majority that the suspension is unwarranted
and illegal. The contention that the President has inherent power to remove or suspend municipal
officers is without doubt not well taken. There is neither statutory nor constitutional provision
granting the President sweeping authority to remove municipal officials. The Constitution provides
that the President "shall . . . exercise general supervision over all local governments," but
supervision does not contemplate control. The President's supervisory authority over municipal
affairs is qualified by the proviso as may be provided by law Clearly, the provision was not to be
self-executing but requires legislative implementation.
Even if, for the sake of argument, the mayor can be removed or suspended for disloyalty to
the Republic, the offense of libel or oral defamation is not disloyalty, dishonesty, or oppression
within the legal or popular meaning of these words. Removal For Cause like "misconduct in
office." has been universally accepted to mean legal cause, and not merely cause which the
appointing power in the exercise of discretion may deem sufficient Moreover, the cause must
relate to and effect the administration of the office and must be restricted to something to a
substantial nature directly affecting the rights and interest of the public. Rudeness of an officer
not amounting to illegality of conduct or oppression is not such misconduct as will give cause for
removing him from office." nothing in the Constitution, law or decision warrants the petitioner's
suspension.

Federico v. COMELEC
Facts:
Edna Sanchez and Osmundo Maligaya were candidates for municipal mayor of Sto. Tomas,
Batangas. Armando Sanchez was the husband of Edna and the gubernatorial candidate for
Batangas. When Armando died a few days before the elections, Edna withdrew her COC for the
position of mayor and filed a new COC for the position of governor as substitute candidate for her
deceased husband. Renato Federico became the substitute candidate for Edna for the position of
mayor. Maligaya opposed this substitution and sought to have Federico ineligible to run because
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
the period to file the COC for substitute candidates have already lapsed after December 14, 2009.
The COMELEC gave due course to the substitution however, the names on the ballots were not
changed since they were already printed. Edna Sanchez won the position for mayor (it was her
name printed on the ballot) however, the Board of Canvassers proclaimed Federico, the substitute
candidate, as the winner. Maligaya then filed a petition to annul the proclamation of Federico as
mayor of Sto. Tomas. The COMELEC En Banc gave due course to Maligaya's petition and annulled
the proclamation.

Issues: Whether or not:
There was a valid substitution of Federico and Sanchez
Maligaya's petition to annul the proclamation was filed on time
Granting that Federico was disqualified, should he be succeeded by Maligaya or the
Vice-Mayor under the local government code (LGC)?

Held:
1. Federico's substitution was not valid. The filing of the substitute COC was filed after the
deadline on December 14, 2009. While it is true that the Omnibus Election Code (BP 881) allows
the substitution of candidates not later than the mid-day of the election, that provision was
superseded by RA 9369. RA 9369 authorizes the use of the Automated Election System and it
mandated COMELEC to set a deadline for the filing of the COC and petition of registration to
participate in the election. The automated system was aimed to improve the transparency and
credibility of election. There was a need for the early printing of the ballots thus the early filing of
the COC's was necessary. As correctly pointed out by the OSG, different dates were set to govern
different situations of the candidates. In case of death or disqualification, the substitute had until
midday of election day to file the COC. In case of a withdrawal, which is the situation at bench,
the substitute only had until December 14, 2009 to file the COC. This is because withdrawal is
voluntary. Generally, a candidate has sufficient time to ponder on his candidacy and to withdraw
while the printing has not yet started. The sudden death of then Governor Armando Sanchez and
the substitution by his widow in the gubernatorial race could not justify a belated substitution in
the mayoralty race.

2. Maligaya's petition to annul the proclamation was field on time. Maligaya became aware of the
Certificate of Canvass of Votes and Proclamation of Winning Candidates (COCVP) in favor of
Federico on May 27, 2010. From that day, he had 10 days to question the dubious proceedings.
Since he filed the petition to annul on Jun 1, 2010, it was indeed filed on time.

3. There being no valid substitution, there was only one qualified candidate Maligaya. Being the
only candidate, he received the highest number of votes. Accordingly, he should be proclaimed as
the duly elected mayor. Considering Maligaya was the winner, there was simply no vacancy thus
the claim that the vice-mayor should succeed under the LGC has no legal basis.

NOTE: If a candidate who obtained the highest number of vote is later declared disqualified or not
eligible, it does not follow that the candidate who obtained the second highest number of votes
will be declared the winner of the elective office. The reason behind this is that the defeated
candidate (2
nd
placer) is not the choice of the people. This rule does not seem to apply to the case
at bar since Federico was not the people's choice it was supposed to be Sanchez. The void
substitution had the effect of nullifying the votes for Sanchez simply because she was not the
proper candidate to begin with. It is like voting for someone whose name is not on the ballot.

2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
NTC v. Hamoy
Facts:
National Transmission Commission (NTC), through its President and CEO,Alan Ortiz,
appointed respondent Hamoy as Vice President for VisMin Operations and Maintenance.
Respondent assumed his duties on March 1, 2003. On January 19, 2004, Oritz issued an order
detailing respondent to NTC's Power Center-Diliman to handle Special Projects (VP for Special
Projects). In 2005, Office Order No. 2005-0256 was issued designating respondent as Officer-In-
Charge (OIC) of the Power Systems Reliability Group (PSRG), concurrent with his duties as Vice
President for Special Projects. Respondent wrote to Ortiz asking that he be returned to his original
assignment as VP of VisMin Operations. He reasoned that his detail already exceeded 1 year and
his designation as OIC of PSRG violated the CSC Memorandum Circular 21 because he did not give
his consent thereto. The NTC Board approved the reassignment of respondent to PSRG and
announced the opening of the position of VP for VisMin Operations. Respondent appealed to the
CSC for the annulment of the order of his reassignment since it violated his security of tenure.
The CSC denied the appeal since respondent was appointed under a third-level position, which
was not station-specific. This means he can be reassigned or transferred from one unit to another
within the same agency without violating his right to security of tenure. The CSC also ruled that
his detail did not exceed the 1 year period as it was superseded by his reassignment to the PSRG.

Issues: Whether or not:
the position of respondent Hamoy was a third-level or second-level position
the position was station-specific
Hamoy's reassignment was made in accordance with civil service law

Held: The reassignment from VP VisMin for Operations to VP for Special Projects was invalid.

There are 3 classes of positions in the career service:
1. First Level clerical, trade, custodial services which involve non-professional or sub-
professional work
2. Second Level technical and scientific positions which involve professional work
3. Third Level positions in the Career Executive Service (CES)

Under the Administrative Code, the CES (3
rd
level) positions belong to those appointed by
the President of the Philippines such as Undersecretary, Assistant Secretary, Bureau Director and
Regional Director. Appointees to CES positions who do not possess the required CES eligibility do
not enjoy security of tenure. Respondent was appointed by the NTC CEO, not by the President of
the Republic. On this basis alone, he cannot be considered part of the CES.

For years, the Commission has promulgated several policies identifying positions in the
Career Service performing executive and managerial functions as belonging to the Third Level
covered by the Career Executive Service (CES) and those outside the CES, thus, requiring third
level eligibility for purposes of permanent appointment and security of tenure. However, to classify
other positions not included in the above enumeration (secretary, regional director, etc) as
covered by the CES and require appointees thereto to acquire CES or CSE eligibility before
acquiring security of tenure will lead to unconstitutional and unlawful consequences. It will result
either: in (1) vesting the appointing power for non-CES positions in the President, in violation of
the Constitution; or, (2) including in the CES a position not held by presidential appointee,
contrary to the Administrative Code.

2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
The position of Hamoy (VP for VisMin Operations) is station-specific. As VisMin stands for
Visayas-Mindanao, respondent necessarily has to hold office in Cebu where NTC has offices for its
Visayas-Mindanao operations. Having been appointed to a station-specific position, whatever
reassignment may be extended to respondent cannot exceed 1 year.

NOTE: A reassignment is a movement of an employee from one organizational unit to another in
the same department or agency which does not involve a reduction in rank, status or salary and
does not require the issuance of an appointment. A detail, on the other hand, is a movement from
one agency to another. Respondents movement was a reassignment (despite the use of the term
detailing in the order of the CEO) as he was moved from one department from another within
the same agency.

Rodriguez v. Tan
Facts:
Petitioner claims that on December 30, 1947, defendant Tan usurped the office of Senator
of the Philippines and until 1949 has continuously collected the salaries and privileges thereto. Tan
filed a motion to dismiss alleging that the Senate Electoral Tribunal judgment is a bar to this
action under res judicata and the Tribunal denied without reservation the claim of petitioner for
damages.

Issue:
Whether or not Tan, who has been proclaimed and discharged the duties of senator, can be
ordered to reimburse the salaries he has received during his incumbency to Rodriguez, who has
been legally declared elected by the Tribunal?

Held:
A de facto officer is still entitled to compensation for services rendered. Tan, who has been
proclaimed and had assumed office, but was later ousted as a result of an election protest, is a de
facto officer during the time he held the office of senator, and is entitled to the compensation,
emoluments and allowances which are provided for the position by the Constitution. This is the
policy and the rule that has been followed consistently in this jurisdiction. The emoluments must
go to the person who rendered service unless the contrary is provided.

Almeda v. Perez
Facts:
A complaint was filed with the Secretary of Justice charging MA with having acquired,
during his incumbency as a government employee, cash and properties from unknown sources.
Such acquisitions were manifestly out of proportion to the salary and other lawful income of MA,
and therefore in violation of RA 1379 (Anti-Graft Law)

After finding that there is reasonable ground to believe that MA committed the acts charged, the
Solicitor General filed a petition for forfeiture against MA. A motion for Leave to Amend Petition for
Forfeiture was field which was subsequently granted by the respondent judge. The amended
petition added other counts and items of alleged unlawful acquisitions and disbursements. The
petitioners objected to the amendment contending that RA 1379 is penal in substance and effect,
hence, the presentation of the amended petition without a previous preliminary investigation
under the Act cannot be allowed; that the amendment would have the effect of presenting a
charge under RA 1379 within 1 year from the date of a general election; and that the amendment
may not be made on a matter of substance after the defendants had pleaded.
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)

Issue: Is the proceeding under RA 1379 civil or criminal?

Held:
1. The proceeding in civil in nature The proceeding for forfeiture is civil in nature and not
criminal. In the first place, a proceeding under the Act does not terminate in the imposition
of a penalty but merely in the forfeiture of properties illegally acquired in favor of the
State. Secondly, the procedure outlined in the Act leading to forfeiture is that provided for
in a civil action. The preliminary investigation required prior to the filing of the petition is
expressly provided to be one similar to a preliminary investigation in a criminal case. If the
investigation is only similar to that in a criminal case, but the other steps in the
proceedings are those for civil proceedings, it stands to reason that the proceeding is not
criminal. Had it been a criminal proceeding there would have been, after a preliminary
investigation, a reading of information, a plea of guilty and a trial thereafter, with the
promulgation of the judgment in the presence of the defendants. These proceedings are
not provided for in the law.

2. As the proceeding for forfeiture is a civil one, amendment of the charges or the petition for
forfeiture may be made as in ordinary civil actions, before trial or in the course of trial
without the need of another investigation. It follows that amendments setting forth newly
discovered acquisitions may be inserted in the petition without obtaining the consent of the
petitioners.

Arias v. Sandiganbayan
Facts:
6 persons were convicted in connection with the overpricing of land purchased by the
Bureau of Public Works. The accused were prosecuted because the parcels of rice land which had
been assessed at Php5.00 per square meter in 1973 were sold as residential land in 1978 fro
Php80.00 per square meter. Petitioners D and A were 2 of the accused. D was then Engineer of
the Province of Rizal who headed and supervised the acquisition of private lands, and A was then
Auditor of Rizal Engineering District who passed upon and approved in audit the acquisition as well
the payment of lands.

Issue: Did the Sandiganbayan commit a reversible error in convicting petitioners in connection
with the overpricing of the lands?

Held:
Yes. The mere fact that the correct valuation is Php5.00 per square meter is insufficient
ground to convict them for overpricing. There can be no overpricing for purposes of criminal
conviction where no proof adduced during orderly proceedings has been presented and accepted.
We could be setting a bad precedent if a head office plagued by common problems dishonest or
negligent subordinates, overwork, multiple assignments or plain incompetence is suddenly
swept into a conspiracy connection simply because he did not primarily examine every single
detail, painstakingly trace every step from inception and investigate the motives of every person
involved in a transaction before affixing his signature as the final approving authority.

Mere signature or approval insufficient to prove conspiracy It can be argued that Arias
should have probed records, inspected documents and questioned persons. It is doubtful if any
auditor for a fairly sized office could personally do all these things in all vouchers presented for his
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
signature. The Court would be asking for the impossible. The auditor is not expected to personally
look into reimbursement voucher's accuracy, propriety and sufficiency. There should be other
grounds than the mere signature or approval to sustain conspiracy charge and conviction. Since
the prosecution has not shown any positive and convincing evidence of conspiracy, the petitioners
are acquitted on grounds of reasonable doubt.

Canonizado v. Aguirre
Facts:
Petitioner was a Commissioner of the National Police Commission (NAPOLCOM). Section 8
of RA 8551 provides, Upon the effectivity of this Act, the terms of current Commissioners are
deemed expired which shall constitute a bar to their reappointment or an extension of their terms
except for current Commissioners who have served less than 2 years of their terms of office who
may be appointed by the President for a maximum term of 2 years.

Petitioner was compelled to leave his position as Commissioner by virtue of section 8 and
accept his appointment of Inspector General of the Internal Affairs Service (IAS). Section 8 was
eventually declared to be violative of petitioner's constitutional right to security of tenure. The
Supreme Court ordered their reinstatement and the payment of full backwages.

Respondents, upon motion for reconsideration, contend that petitioner must be deemed to
have abandoned his claim for reinstatement to NAPOLCOM since the offices of NAPOLCOM
Commissioner and Inspector General of IAS are incompatible.

Issue: Whether petitioner's acceptance of the IAS position should result in an abandonment of his
claim for reinstatement to the NAPOLCOM

Held:
Canonizado harbored no willful desire or intention to abandon his official duties. In fact,
he lost no time disputing what they perceived to be an illegal removal. The removal of
the petitioners by virtue of the provisions of said law does not amount to voluntary
relinquishment.
It is well stated rule that he who, while occupying one office, accepts another
incompatible with the first, ipso facto vacates the first office and his title is thereby
terminated without any other act or proceeding. However, this rule does not apply in
the case at bar because at no point did Canonizado discharge the functions of the two
offices simultaneously. He was forced out of his first office by the enactment of section
8 of RA 8551. The rule on incompatibility of duties never came into play since petitioner
never occupied the two positions concurrently.
Canonizado was compelled to leave his office by an unconstitutional provision of law.
He held a second office during the period that his appeal was pending. A contrary ruling
would deprive petitioner his right to earn a living and a right to lead a productive life.
Prohibiting him from accepting a second position during the pendency of his position
would be to unjustly compel him to bear the consequences of an unconstitutional act
which cannot be attributed to him. However, before Canonizado can re-assume his post
as Commissioner, he should first resign as Inspector General of IAS.

Sinaca v. Mula
Facts:
During the 1998 elections, the two opposing factions of the ruling party LAKAS-NUCD-
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
UMPD (LAKAS) filled in separate candidates for the position of mayor of the Municipality of
Malimano, Surigao del Norte. One faction headed by Robert Z. Barbers (hereafter BARBERS
Wing) nominated Grachil G. Canoy (CANOY), while the other group lead by Francisco T. MATUGAS
(hereafter MATUGAS Wing) endorsed the candidacy of Teodoro F. Sinaca, Jr. (TEODORO).

Miguel H. Mula (MULA), a candidate for vice-mayor and belonging to the BARBERS Wing,
filed before the COMELEC a petition for disqualification against TEODORO. The COMELEC issued a
resolution disqualifying TEODORO as candidate for mayor and ordering the cancellation of his COC
because of prior conviction of bigamy, a crime involving moral turpitude.

Petitioner Emmanuel D. Sinaca, (EMMANUEL), an independent candidate, withdrew his
certificate of candidacy for Sangguniang Bayan Member, joined and became a member of the
LAKAS party and was nominated by the LAKAS MATUGAS Wing as the substitute mayoralty
candidate for the Municipality of Malimono. He then filed his COC on the basis of such nomination.
Mula opposed the substitution on the following grounds:

a. The substitute, before he filed his Certificate of Candidacy as LAKAS candidate, was an
independent candidate. Being so, he cannot rightfully substitute the disqualified one;

b. Substitution generally takes place when by reason of a candidates disqualification the
party to which he belongs loses such representation. In the instant case, the
disqualification did not at all prejudice LAKAS NUCD-UMDP because Mr. Garchil G. Canoy
is still there representing the party after the disqualification.

Issue: Whether or not the substitution of EMMANUEL was valid

Held: The substitution was valid

EMMANUEL was properly nominated as substitute candidate by the LAKAS party MATUGAS
wing to which TEODORO, the disqualified candidate. The fact that EMMANUEL was an
independent candidate prior to his nomination is immaterial. What is more significant is that he
had previously withdrawn his certificate of candidacy as independent candidate for Sangguniang
member before he filed his certificate of candidacy as a substitute for TEODORO at which time he
was, for all intents and purposes, already deemed a member of the LAKAS party MATUGAS wing.
Even the fact that EMMANUEL only became a member of the LAKAS party after the disqualification
of TEODORO, will not affect the validity of the substitution. There is nothing in the Constitution or
the statute which requires as a condition precedent that a substitute candidate must have been a
member of the party concerned for a certain period of time before he can be nominated as such.

It stands to reason that with the disqualification of TEODORO, who is a member of the
LAKAS MATUGAS wing, the substitute must come from the same faction as the candidate to be
substituted and since it was MATUGAS who indorsed the nomination of TEODORO, then MATUGAS
nomination of EMMANUEL in substitution of TEODORO is sufficient and in order.

Quinto v. COMELEC
Facts:
Petitioners Eleazar P. Quinto and Gerino A. Tolentino, Jr. filed a petition for certiorari and
prohibition against the COMELEC for issuing a resolution declaring appointive officials who filed
their certificate of candidacy as ipso facto resigned from their positions. In this defense, the
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)
COMELEC avers that it only copied the provision from Sec. 13 of R.A. 9369.
Issue: Whether or not the said COMELEC resolution was valid.

Held:
NO. In the Farias case, the petitioners challenged Sec. 14 of RA. 9006 repealing Sec. 66
of the Omnibus Election Code (OEC) for giving undue benefit to elective officials in comparison
with appointive officials. Incidentally, the Court upheld the substantial distinctions between the
two and pronounced that there was no violation of the equal protection clause. However in the
present case, the Court held that the discussion on the equal protection clause was an obiter
dictum since the issue raised therein was against the repealing clause. It didn't squarely challenge
Sec. 66.

Sec. 13 of RA. 9369 unduly discriminated appointive and elective officials. Applying the 4
requisites of a valid classification, the proviso does not comply with the second requirement that
it must be germane to the purpose of the law.

The obvious reason for the challenged provision is to prevent the use of a governmental
position to promote one's candidacy, or even to wield a dangerous or coercive influence of the
electorate. The measure is further aimed at promoting the efficiency, integrity, and discipline of
the public service by eliminating the danger that the discharge of official duty would be motivated
by political considerations rather than the welfare of the public. The restriction is also justified by
the proposition that the entry of civil servants to the electorate arena, while still in office, could
result in neglect or inefficiency in the performance of duty because they would be attending to
their campaign rather than to their office work.
Sec. 13 of RA. 9369 pertains to all civil servants holding appointive posts without distinction as to
whether they occupy high positions in government or not. Certainly, a utility worker in the
government will also be considered as ipso facto resigned once he files his certificate of candidacy
for the election. This scenario is absurd for, indeed, it is unimaginable how he can use his position
in the government to wield influence in the political world.

The provision s directed to the activity any and all public offices, whether they be partisan
or non partisan in character, whether they be in the national, municipal or barangay level.
Congress has not shown a compelling state interest to restrict the fundamental right involved on
such a sweeping scale.

MOTION FOR RECONSIDERATION

Facts:
This is a motion for reconsideration filed by the Commission on Elections. The latter moved
to question an earlier decision of the Supreme Court declaring Section 4 (a) of COMELEC
Resolution No. 8678 unconstitutional. Section 4 (a) of COMELEC Resolution No. 8678 provides
that, Any person holding a public appointive office or position including active members of the
Armed Forces of the Philippines, and other officers and employees in government-owned or
controlled corporations, shall be considered ipso facto resigned from his office upon the filing of
his certificate of candidacy. Be it noted that petitioners of the above-entitled case are appointive
officials who intend to be elected in the previously held 2010 elections and who felt aggrieved by
the issuance of the questioned resolution.

Issue: Whether or not Section 4 (a) of COMELEC Resolution No. 8678 is constitutional.
2-D [ATTY. ERENETA]
L.T.J.F. 2
nd
th
ed. 2010)

Held:
The Supreme Court overruled its previous decision declaring the assailed resolution
unconstitutional. Here, it strongly upholds the constitutionality of the resolution saying that it does
not violate the equal protection clause. It is settled that the equal protection clause does not
demand absolute equality; it merely requires that all persons shall be treated alike, under like
circumstances and conditions both as to privileges conferred and liabilities enforced. The test used
is reasonableness which requires that:

1. The classification rests on substantial distinctions;
2. It is germane to the purposes of the law;
3. It is not limited to existing conditions only; and
4. It applies equally to all members of the same class.

In the case under consideration, there is a substantial distinction between public and elective
officials which has been rendered moot and academic by the ruling made in the case of Farinas,
etl. al. vs. Executive Secretary, et. al.

Section 4 (a) of COMELEC Resolution No. 8678 is constitutional.

(source: http://philippinelaw.info/case-digests/quinto-v-comelec.html)

Admin Law Review

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Admin Law Review

Uploaded by

Copyright:

Available Formats

ATENEO LAW SCHOOL ADMINISTRATIVE LAW

2-D [ATTY. ERENETA]

You might also like