Powers of the

President
Summarized Discussion and Cases
Submitted by:
Megan Areno
Lorelei Joselle Bucu
Elisha Eloriaga
CONSTI1 Section 1C, 1st Semester, SY 2014-2015
Submitted to:
Justice Francisco P. Acosta
September 25, 2014

Powers of the President

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Table of Contents
I. Executive Power ............................................................................................................. 1
II. Power of Administrative Reorganization ........................................................... 2
III. Power of Appointment .............................................................................................. 2
IV. Power of Removal ........................................................................................................ 6
V. Power of Control and Supervision ......................................................................... 6
VI. Military Power ............................................................................................................ 14
VII. Pardoning Power ..................................................................................................... 22
VIII. Borrowing Power ................................................................................................... 26
IX. Diplomatic Power...................................................................................................... 27
X. Budgetary Power ........................................................................................................ 30
XI. Informing Power ....................................................................................................... 31
XII. Residual Power ......................................................................................................... 31
XIII. Other Powers ............................................................................................................ 32

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Powers of the President

Summarized Discussion and Cases

The President of the Republic of the Philippines is vested with plethora of powers, which
allows him to diligently perform his duties and responsibilities. These powers are
expressly stated in the Constitution and other statutes. A summary of concepts and
discussion of the different powers of the President are provided as follows:

I.

Executive Power
Const. Art. VII, Sec. 1:
The executive power shall be vested in the President of the Philippines.

Executive Power Defined

Enforcement and enactment of laws, conduct of foreign affairs, the command of the armed
forces, the administration of the government and even the crystallization of public opinion
on vital issues
Executive Ordinance Powers

Executive Orders acts of the President providing for rules of a general or

permanent character
Administrative Orders acts of the President which relate to particular aspects of
governmental operations
Proclamations acts of the President fixing a date or declaring a status or condition
of public moment or interest
Memorandum Orders acts of the President on matters of administrative detail
Memorandum Circular acts of the President on matter relating to internal
administration
General or Special Orders acts and commands of the President in his capacity as
Commander-in-Chief of the AFP

Powers of the President

II.

Power of Administrative Reorganization

The 1987 Administrative Code gives the President continuing authority to re-organize and
redefine the functions of the Office of the President. To remain effective and efficient, the
Office must be capable of being shaped and reshaped by the President in the manner he
deems fit to carry out his directives and policies including modification of functions of such
executive agencies as the exigencies of the service may require.
Power to Reorganize the Office of the President Proper [Sec. 31 (1), EO 292]

By abolishing, consolidating or merging units, or by transferring functions from one

unit to another

Power to Reorganize the Office of the President [Sec. 31 (2&3), EO 292]

III.

Power to reorganize offices outside the Office of the President Proper but still
within the Office of the President
Limited to merely transferring functions or agencies from the Office of the President
to Departments or Agencies and vise versa

Power of Appointment

Appointment Defined
The selection, by the authority vested with the power, of an individual who is to exercise
the functions of a given office
May be exercised by the legislature, by the judiciary and by the Constitutional
Commissions, over their own respective personnel
May be made verbally but usually done in writing
The Commission written evidence of an appointment
Designation Defined
Simply means imposition of additional duties on a person already in the public service

Powers of the President

Officials subject to the Appointment of the President

A. With Consent of the Commission on Appointments (Sec. 16, Article VII)
1. Heads of the Executive Department
Except: Vice-Presidentmay be appointed as a Member of the Cabinet. Such
appointment requires no confirmation. (Sec. 3, Article VII)
2. Ambassadors, other public ministers and consuls
3. Officers of the Armed Forces from the rank of colonel or naval captain
4. Other officers whose appointments are vested in him in the Constitution
Example: Judicial Bar Council, Constitutional Commissions
5. All other officers of the government whose appointments are not otherwise
provided by law
6. Those whom he may be authorized by law to appoint
B. With Prior recommendation or nomination by the Judicial and Bar Council (JBC)
1. Members of the Supreme Court and all lower courts (Sec. 9, Article VIII)
2. Ombudsman and his 5 Deputies (Sec. 9, Article XI)
C. Appointment of VP as Member of the Cabinet
D. Appointment solely by the President
1.
2.
3.
4.

Those vested by the Constitution on the President alone

Those whose appointments are not otherwise provided for by law
Those who may be authorized by law to appoint;
Those other officers lower in rank whose appointment is vested by law in the
President alone (Sec. 16, Article VII)

Classification of Appointment

Permanent Appointments those extended to persons possessing the requisite

eligibility and are thus protected by the constitutional provision on security of
tenure
Temporary Appointments given to persons without such eligibility, are revocable
at will and without the necessity of just cause or a valid investigation
Regular (see succeeding table)

Powers of the President

Ad Interim (see succeeding table)

Regular Appointment

Ad Interim Appointment

Made during the legislative session

Made during the recess

Made only after the nomination is

confirmed by the COA

Appointment is made before the

confirmation

Once confirmed by the COA, continues until

the end of the term of the appointee

Appointment is deemed by-passed

through inaction of, and so disapproved
impliedly by the COA

Appointing Procedure
A. For Regular Appointment:
1.
2.
3.
4.

Nomination by the President

Confirmation by the Commission on Appointments
Issuance of the Commission (also done by the President)
Acceptance by the appointee

Note: Appointment is deemed complete upon acceptance. Pending such acceptance, which
is optional to the appointee, the appointment may still be validly withdrawn. Appointment
to a public office cannot be forced upon citizen except for purposes of defense of the State
under Section 4, Article II of the Constitution, as an exception to the rule against
involuntary servitude.
B. For Ad Interim Appointment:
1. Appointment (Same as steps 1, 3, 4 for regular appointment)
2. Confirmation
Note: For appointments that do not require confirmation, step 2 is skipped.
Limitations on Appointing Power

Powers of the President

1. Sec. 13 par. 1, Art. VII on Multiple Offices The Members of the Cabinet and their
deputies and assistants shall not, unless otherwise provided by Constitution hold
any other office or employment during their tenure.
2. Sec. 13 par. 2, Art. VII on Anti-Nepotism The spouse and relatives by
consanguinity or affinity within the 4th civil degree of the President shall not during
his tenure be appointed as Members of the Constitutional Commissions, or the
Office of the Ombudsman, or as Secretaries, Undersecretaries, chairmen or heads of
bureaus or offices, including government-owned or controlled corporations and
their subsidiaries.
3. Sec. 14, Art. VII Appointments extended by an Acting President shall remain
effective unless revoked by the elected President within 90 days from his
assumption of office.
4. Sec. 15, Art. VII on Midnight Appointments* Two months immediately before the
net presidential elections and up to the end of his term, a President or Acting
President shall not make appointments except temporary appointments to
executive positions when continued vacancies therein will prejudice public service
or endanger public safety.
*Midnight appointment appointment made by the President after the election of
his successor and up to the end of his term. This is generally prohibited by the
Constitution.
5. Sec. 16 par. 2, Art. VII The President shall have the power to make appointments
during the recess of the Congress, whether voluntary or compulsory, but such
appointments shall be effective only until disapproval by the COA or until the next
adjournment of the Congress.
Other Limitations:

The Presidents power of appointment may also be limited by the Congress through
its power to prescribe qualifications for public office.
The Judiciary may annul an appointment by the President if the appointee has not
been validly confirmed or does not possess the required qualifications.

Powers of the President

IV.

Power of Removal

As a general rule, the appointing power impliedly carries with it the power to removal.
However, as an exception, those appointed by him where the Constitution prescribes
certain methods for separation from public service (e.g. impeachment) are not covered.
Examples are as follows:

Members of Supreme Court, Ombudsman and Constitutional Commission - may only

be removed by impeachment (Sec. 2, Article XI)
Judges of inferior courts subject to disciplinary authority and may be removed
only by the Supreme Court (Sec. 11, Article VIII)

The President is also without any power to remove elected officials, since the power is
exclusively vested in the proper courts as provided by last paragraph of Section 60 of the
Local Government Code.
In all other cases, the power of removal may be exercised only for cause as may be
provided by law and in accordance with the prescribed administrative procedure. (Sec. 2
par. 3, Article IX-B)
Examples of appointees covered by the power of removal:

V.

Members of career service of the Civil Service who are appointed by the President
may be directly disciplined by him and removed provided that the same is for cause
and in accordance with the procedure prescribe by the law
Members of the Cabinet whose continuity in office depends upon the President may
be replaced at any time

Power of Control and Supervision

Const. Art. VII, Sec. 17:
The resident shall have control of all the executive departments, bureaus
and offices. He shall ensure that the laws be faithfully executed.

Powers of the President

Section 17 is a self-executing provision. The President derives his power of control directly
from the Constitution and NOT from any implementing legislation.
This justifies an executive action to carry out reorganization measures under a broad
authority of law.
Control vs. Supervision
Control

The power of an officer to alter or

to modify or nullify or set aside
what a subordinate officer had
done in the performance of his
duties and to substitute judgment
of the former for that of the latter
Authority to order the doing of such
an act by a subordinate or to undo
such act or to assume a power
directly vested in him by law
Stronger in power

Supervision

Overseeing or the power of the

authority of an officer to see that
the subordinate officers perform
their duties.

Drilon vs. Lim (GR No. 112497, August 4, 1994)

Facts:
Pursuant to Section 187 of the Local Government Code, the Secretary of Justice had, on
appeal to him of four oil companies and a taxpayer, declared Ordinance No. 7794,
otherwise known as the Manila Revenue Code, null and void for non-compliance with the
prescribed procedure in the enactment of tax ordinances and for containing certain
provisions contrary to law and public policy.
In a petition for certiorari filed by the City of Manila, the Regional Trial Court of Manila
revoked the Secretarys resolution and sustained the ordinance, holding inter alia that the
procedural requirements had been observed. More importantly, it declared Section 187 of
the Local Government Code as unconstitutional because of its vesture in the Secretary of
Justice of the power of control over local governments in violation of the policy of local
autonomy mandated in the Constitution and of the specific provision therein conferring on
Powers of the President

the President of the Philippines only the power of supervision over local governments. The
court cited the familiar distinction between control and supervision, the first being the
power of an officer to alter or modify or set aside what a subordinate officer had done in
the performance of his duties and to substitute the judgment of the former for the latter,
while the second is the power of a superior officer to see to it that lower officers perform
their functions is accordance with law.
Issues:
(1) Whether or not Section 187 of the Local Government Code is unconstitutional; and
(2) Whether or not the Secretary of Justice can exercise control, rather than supervision,
over the local government
Held:
The judgment of the lower court is reversed in so far as its declaration that Section 187 of
the Local Government Code is unconstitutional but affirmed the said lower courts finding
that the procedural requirements in the enactment of the Manila Revenue Code have been
observed.
Section 187 authorizes the Secretary of Justice to review only the constitutionality or
legality of the tax ordinance and, if warranted, to revoke it on either or both of these
grounds. When he alters or modifies or sets aside a tax ordinance, he is not also permitted
to substitute his own judgment for the judgment of the local government that enacted the
measure. Secretary Drilon did set aside the Manila Revenue Code, but he did not replace it
with his own version of what the Code should be.
An officer in control lays down the rules in the doing of an act. It they are not followed, he
may, in his discretion, order the act undone or re-done by his subordinate or he may even
decide to do it himself. Supervision does not cover such authority. The supervisor or
superintendent merely sees to it that the rules are followed, but he himself does not lay
down such rules, nor does he have the discretion to modify or replace them. In the opinion
of the Court, Secretary Drilon did precisely this, and no more nor less than this, and so
performed an act not of control but of mere supervision.
Regarding the issue on the non-compliance with the prescribed procedure in the
enactment of the Manila Revenue Code, the Court carefully examined every exhibit and
agree with the trial court that the procedural requirements have indeed been observed.
Powers of the President

The only exceptions are the posting of the ordinance as approved but this omission does
not affect its validity, considering that its publication in three successive issues of a
newspaper of general circulation will satisfy due process.
Control

Supervision

Officer:
Lays down the rules in the doing of
an act.
NOT followed, he may, in his
discretion, order the act undone or
re-done by his subordinate or he
may even decide to do it himself.

Supervisor/superintendent:
Merely sees to it that the rules are
followed, but he himself does NOT
lay down such rules, nor does he
have the discretion to modify or
replace them.
CANNOT prescribe his own
manner for the doing of the act.
No judgment on this matter except
to see to it that the rules are
followed.

Doctrine of Qualified Political Agency/Alter ego principle

President has full control of all the members of the Cabinet subject at all times to
the disposition of the President since they are merely his alter ego.

Heads of various departments and their personalities are, in reality, but the
projection of that of the President. Acts performed and promulgated in the regular
course of business, are, unless disapproved or reprobated by the Chief Executive,
presumptively acts of the Chief Executive.

This is not applicable to acts of cabinet secretaries done in their capacity as ex

officio board directors of a government-owned or controlled corporation of which
they become members NOT by appointment of the President but by the authority of
the law.

Villena vs. Secretary of the Interior (G.R. No. 46570, April 21, 1939)
Facts:
Jose Villena was the then mayor of Makati in the 1930s. After investigation, the Secretary of
Interior recommended the suspension of Villena with the Office of the president who
approved the same. The Secretary then suspended Villena. Villena averred claiming that
Powers of the President

the Secretary has no jurisdiction over the matter. The power or jurisdiction is lodged in the
local government [the governor] pursuant to Section 2188 of the Administrative Code.
Further, even if the respondent Secretary of the Interior has power of supervision over
local governments, that power, according to the constitution, must be exercised in
accordance with the provisions of law and the provisions of law governing trials of charges
against elective municipal officials are those contained in Section 2188 of the
Administrative Code as amended. In other words, the Secretary of the Interior must
exercise his supervision over local governments, if he has that power under existing law, in
accordance with sec 2188 of the Administrative Code, as amended, as the latter provisions
govern the procedure to be followed in suspending and punishing elective local officials
while Section 79(c) of the Administrative Code is the genera law which must yield to the
special law.
Issue:
Whether or not the Secretary of Interior can suspend an LGU official under investigation?
Held:
Yes. There is no clear and express grant of power to the secretary to suspend a mayor of
a municipality who is under investigation. On the contrary, the power appears lodged in
the provincial governor by sec 2188 of the Administrative Code which provides that The

provincial governor shall receive and investigate complaints made under oath against
municipal officers for neglect of duty, oppression, corruption or other form of
maladministration of office, and conviction by final judgment of any crime involving moral
turpitude.
The fact, however, that the power of suspension is expressly granted by Section 2188 of the
Administrative Code to the provincial governor does not mean that the grant is necessarily
exclusive and precludes the Secretary of the Interior from exercising a similar power. For
instance, Villena admitted in the oral argument that the President of the Philippines may
himself suspend the petitioner from office in virtue of his greater power of removal (sec.
2191, as amended, Administrative Code) to be exercised conformably to law. Indeed, if the
President could, in the manner prescribed by law, remove a municipal official; it would be a
legal incongruity if he were to be devoid of the lesser power of suspension. And the
incongruity would be more patent if, possessed of the power both to suspend and to
remove a provincial official (sec. 2078, Administrative Code), the President were to be
without the power to suspend a municipal official. The power to suspend a municipal
Powers of the President

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official is not exclusive. Preventive suspension may be issued to give way for an impartial
investigation.
Heads of various departments and their personalities are, in reality, but the projection of
that of the President. Acts performed and promulgated in the regular course of business,
are, unless disapproved or reprobated by the Chief Executive, presumptively acts of the
Chief Executive.

Doctrine of exhaustion of administrative remedies

It has been consistently held by the Supreme Court, in a long line of cases, that before a
party is allowed to seek the intervention of the court, it is a pre-condition that he should
have availed of all the means of administrative processes afforded him. Hence, if a remedy
within the administrative machinery can still be resorted to by giving the administrative
officer concerned every opportunity to decide on a matter that comes within his
jurisdiction, then such remedy should be exhausted first before the courts judicial power
can be sought.
Manubay vs. Garilao (GR No. 140717, April 16, 2009)
Facts:
At the heart of this controversy is a 124-hectare land in Barrio Cadlan, Pili, Camarines Sur
owned by petitioners Annie, Anne Marie, James John, James Francis and Anne Margareth
(all surnamed Manubay) and Manubay Agro-Industrial Development Corporation. The
Municipal Agrarian Reform placed a notice of coverage converting the property under the
comprehensive agrarian reform program, which petitioners did not protest. Afterwards, an
resolution was passed approving the CARP in the Municipality of Pili, Camarines Sur which
reclassified the land from agricultural to highly urbanized intended for mixed residential
and commercial use. Petitoners requested for this to be set aside and to be converted back
but was denied by then DAR Regional Director and DAR Secretary Ernesto Garilao.
On April 28, 1998, petitioners filed a petition for certiorari in the Court of Appeals (CA)
assailing the denial of their application for conversion. They averred that respondent acted
with grave abuse of discretion when he denied their application. According to them, the
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issuance of a mere notice of coverage placing agricultural land under the CARP was not a
ground for the denial of such application.
In a resolution dated June 1, 1999, the CA dismissed the petition. DAR-AO No. 7, s. 1997
provides that the decision of the DAR Secretary may be appealed either to the Office of the
President (OP) or to the CA. Considering that the issue raised by petitioners involved the
administrative implementation of the CARP, the OP was more competent to rule on the
issue. Moreover, by failing to bring the matter to the said office, petitioner did not exhaust
all available administrative remedies before resorting to a petition for certiorari.

Issue:
Whether or not the CA erred in dismissing the petition for certiorari?
Held:
Yes. Under the doctrine of qualified political agency, department secretaries are alter egos
or assistants of the President and their acts are presumed to be those of the latter unless
disapproved or reprobated by him. Thus, as a rule, an aggrieved party affected by the
decision of a cabinet secretary need not appeal to the OP and may file a petition for
certiorari directly in the Court of Appeals assailing the act of the said secretary. Needless to
state, elevating the matter to the OP was consistent with the doctrine of exhaustion of
administrative remedies. A party aggrieved by an order of an administrative official should
first appeal to the higher administrative authority before seeking judicial relief. Otherwise,
as in this case, the complaint will be dismissed for being premature or for having no cause
of action.
This is NOT necessary or required when there exists a special law that provides for a
different mode of appeal.
The Take-Care Clause

The power to take care that the laws be faithfully executed makes the President a
dominant figure in the administration of the government.
Until a law is declared unconstitutional, the President has the duty to execute it
regardless of his doubts to its validity.

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The power to conduct investigations to aid him in ensuring the faithful execution of
laws is inherent in the Presidents powers as the Chief Executive.
The obligation to see to it that laws are faithfully executed necessitates the
corresponding power in the President to conduct investigations into the conduct of
officials and employees in the executive department.

Biraogo vs. The Philippine Truth Commission (2010)

Indeed, the Executive is given much leeway in ensuring that our laws are faithfully
executed. As stated above, the powers of the President are not limited to those specific
powers under the Constitution. One of the recognized powers of the President granted
pursuant to this constitutionally-mandated duty is the power to create ad hoc committees.
This flows from the obvious need to ascertain facts and determine if laws have been
faithfully executed. It should be stressed that the purpose of allowing ad hoc investigating
bodies to exist is to allow an inquiry into matters which the President is entitled to know so
that he can be properly advised and guided in the performance of his duties relative to the
execution and enforcement of the laws of the land.
Power of Supervision over LGUs

Const. Art. X, Sec. 4:

The President of the Philippines shall exercise general supervision over
local governments. Provinces with respect to component cities and
municipalities, and cities and municipalities with respect to component
barangays, shall ensure that the acts of their component units are within the
scope of their prescribed powers and functions.
Const. Art. X, Sec. 16:
The President shall exercise general supervision over autonomous regions to
ensure that laws are faithfully executed.
The power of the President over local governments is only one of general supervision. The
President can only interfere in the affairs and activities of a local government unit if he
finds that the latter had acted contrary to law (Judge Dadole v. COA).

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VI.

Military Power
Const. Art. VII, Sec. 18:
The President shall be the Commander-in-Chief of all armed forces of the
Philippines and whenever it becomes necessary, he may call out such armed
forces to prevent or suppress lawless violence, invasion or rebellion. In case
of invasion or rebellion, when the public safety requires it, he may, for a
period not exceeding sixty days, suspend the privilege of the writ of habeas
corpus or place the Philippines or any part thereof under martial law. Within
forty-eight hours from the proclamation of martial law or the suspension of
the privilege of the writ of habeas corpus, the President shall submit a report
in person or in writing to the Congress. The Congress, voting jointly, by a
vote of at least a majority of all its Members in regular or special session, may
revoke such proclamation or suspension, which revocation shall not be set
aside by the President. Upon the initiative of the President, the Congress
may, in the same manner, extend such proclamation or suspension for a
period to be determined by the Congress, if the invasion or rebellion shall
persist and public safety requires it.
The Congress, if not in session, shall, within twenty-four hours following
such proclamation or suspension, convene in accordance with its rules
without need of a call.
The Supreme Court may review, in an appropriate proceeding filed by any
citizen, the sufficiency of the factual basis of the proclamation of martial law
or the suspension of the privilege of the writ or the extension thereof, and
must promulgate its decision thereon within thirty days from its filing.
A state of martial law does not suspend the operation of the Constitution, nor
supplant the functioning of the civil courts or legislative assemblies, nor
authorize the conferment of jurisdiction on military courts and agencies over
civilians where civil courts are able to function, nor automatically suspend
the privilege of the writ.

Powers of the President

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The suspension of the privilege of the writ shall apply only to persons
judicially charged for rebellion or offenses inherent in or directly connected
with invasion.
During the suspension of the privilege of the writ, any person thus arrested
or detained shall be judicially charged within three days, otherwise he shall
be released.
This section bolsters Article II, Sec. 3 that civilian authority is at all times supreme over the
military by making the President commander-in-chief of all the armed forces, which
lessens the danger of a military take-over of the government in violation of its republican
nature.
The military power enables the President to:
a. Command all the armed forces of the Philippines
b. Suspend the privilege of the writ of habeas corpus
c. Declare martial law

G. Command of the Armed Forces

Power of the sword

Plans all campaigns, establishes all sieges and blockades, directs all marches, and
fights all battles
To call out the Armed Forces to prevent or suppress lawless violence, invasion or
rebellion
The factual determination to call out the Armed Forces is a political question which
the President necessarily exercises as a discretionary power solely vested in his
wisdom. However, the Court can examine whether such power was exercised within
permissible constitutional limits or whether it was exercised in a manner
constituting grave abuse of discretion. It is incumbent upon the petitioner to show
that the Presidents decision is totally bereft of factual basis. If there is no such
proof, the Court shall not interfere with the Presidents judgment.
The calling out power involves ordinary police power.

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Court Martials

Agencies of executive character which may be convened by the President

independently of legislation and by virtue only of his constitutional function as
commander-in-chief.
Do NOT pertain to the judiciary and are utilized by him in properly commanding
and enforcing such discipline in the Armed Forces.
The power to confirm a sentence of the President, as Commander-in-Chief, includes
the power to approve or disapprove the entire or any part of the sentence given by
the court martial.

Olaguer vs. Miliatry Commission No. 34 (G.R. No. L-54558, May 22, 1987)
Facts:
In 1979, Olaguer and some others were detained by military personnel and they were
placed in Camp Bagong Diwa. Logauer and his group are all civilians. They were charged
with (1) unlawful possession of explosives and incendiary devices; (2) conspiracy to
assassinate President and Mrs. Marcos; (3) conspiracy to assassinate cabinet members
Juan Ponce Enrile, Francisco Tatad and Vicente Paterno; (4) conspiracy to assassinate
Messrs. Arturo Tangco, Jose Roo and Onofre Corpus; (5) arson of nine buildings; (6)
attempted murder of Messrs. Leonardo Perez, Teodoro Valencia and Generals Romeo
Espino and Fabian Ver; and (7) conspiracy and proposal to commit rebellion, and inciting
to rebellion. On August 19, 1980, the petitioners went to the SC and filed the instant
Petition for prohibition and habeas corpus.
Issue:
Whether or not a military tribunal has the jurisdiction to try civilians while the civil courts
are open and functioning?
Held:
The SC nullified for lack of jurisdiction all decisions rendered by the military courts or
tribunals during the period of martial law in all cases involving civilian defendants. A
military commission or tribunal cannot try and exercise jurisdiction, even during the
period of martial law, over civilians for offenses allegedly committed by them as long as the
civil courts are open and functioning, and that any judgment rendered by such body
Powers of the President

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relating to a civilian is null and void for lack of jurisdiction on the part of the military
tribunal concerned.
David vs. Arroyo (GR No. 171396, May 3, 2006)
Facts:
In February 2006, due to the escape of some Magdalo members and the discovery of a plan
(Oplan Hackle I) to assassinate the president, then president Gloria Macapagal-Arroyo
(GMA) issued Presidential Proclamation1017 (PP1017) and is to be implemented by
General Order No. 5 (GO 5). The said law was aimed to suppress lawlessness and the
connivance of extremists to bring down the government.
Pursuant to such PP, GMA cancelled all plans to celebrate EDSA I and at the same time
revoked all permits issued for rallies and other public organization/meeting.
Notwithstanding the cancellation of their rally permit, Kilusang Mayo Uno (KMU) head
Randolf David proceeded to rally which led to his arrest.
Later that day, the Daily Tribune, which Cacho-Olivares is the editor, was raided by the
CIDG and they seized and confiscated anti-GMA articles and write ups. Later still, another
known anti-GMA news agency (Malaya) was raided and seized. On the same day, Beltran of
Anakpawis, was also arrested. His arrest was however grounded on a warrant of arrest
issued way back in 1985 for his actions against Marcos. His supporters cannot visit him in
jail because of the current imposition of PP 1017 and GO 5.
In March, GMA issued PP 1021 which declared that the state of national emergency ceased
to exist. David and some opposition Congressmen averred that PP1017 is unconstitutional
for it has no factual basis and it cannot be validly declared by the president for such power
is reposed in Congress. Also such declaration is actually a declaration of martial law.
Olivares-Cacho also averred that the emergency contemplated in the Constitution are those
of natural calamities and that such is an overbreadth. Petitioners claim that PP 1017 is an
overbreadth because it encroaches upon protected and unprotected rights. The Sol-Gen
argued that the issue has become moot and academic by reason of the lifting of PP 1017 by
virtue of the declaration of PP 1021. The Sol-Gen averred that PP 1017 is within the
presidents calling out power, take care power and take over power.
Issue:
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17

Whether or not PP 1017 and GO 5 is constitutional?

Held:
PP 1017 and its implementing GO are partly constitutional and partly unconstitutional. The
issue cannot be considered as moot and academic by reason of the lifting of the questioned
PP. It is still in fact operative because there are parties still affected due to the alleged
violation of the said PP. Hence, the SC can take cognition of the case at bar. The SC ruled
that PP 1017 is constitutional in part and at the same time some provisions of which are
unconstitutional. The SC ruled in the following way:
Resolution by the SC on the Factual Basis of its declaration
The petitioners were not able to prove that GMA has no factual basis in issuing PP 1017
and GO 5. A reading of the Solicitor Generals Consolidated Comment and Memorandum
shows a detailed narration of the events leading to the issuance of PP 1017, with
supporting reports forming part of the records. Mentioned are the escape of the Magdalo
Group, their audacious threat of the Magdalo D-Day, the defections in the military,
particularly in the Philippine Marines, and the reproving statements from the communist
leaders. There was also the Minutes of the Intelligence Report and Security Group of the
Philippine Army showing the growing alliance between the NPA and the
military. Petitioners presented nothing to refute such events. Thus, absent any contrary
allegations, the Court is convinced that the President was justified in issuing PP 1017
calling for military aid. Indeed, judging the seriousness of the incidents, GMA was not
expected to simply fold her arms and do nothing to prevent or suppress what she believed
was lawless violence, invasion or rebellion. However, the exercise of such power or duty
must not stifle liberty.
Resolution by the SC on the Overbreadth Theory
First and foremost, the overbreadth doctrine is an analytical tool developed for testing on
their faces statutes in free speech cases. The 7 consolidated cases at bar are not primarily
freedom of speech cases. Also, a plain reading of PP 1017 shows that it is not primarily
directed to speech or even speech-related conduct. It is actually a call upon the AFP to
prevent or suppress all forms of lawless violence. Moreover, the overbreadth doctrine is
not intended for testing the validity of a law that reflects legitimate state interest in
maintaining comprehensive control over harmful, constitutionally unprotected conduct.
Undoubtedly, lawless violence, insurrection and rebellion are considered harmful and
constitutionally unprotected conduct. Thus, claims of facial overbreadth are entertained in
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cases involving statutes which, by their terms, seek to regulate only spoken words and
again, that overbreadth claims, if entertained at all, have been curtailed when invoked
against ordinary criminal laws that are sought to be applied to protected conduct. Here,
the incontrovertible fact remains that PP 1017 pertains to a spectrum of conduct, not free
speech, which is manifestly subject to state regulation.
Resolution by the SC on the Calling Out Power Doctrine
On the basis of Sec 17, Art 7 of the Constitution, GMA declared PP 1017. The SC considered
the Presidents calling-out power as a discretionary power solely vested in his wisdom, it
stressed that this does not prevent an examination of whether such power was exercised
within permissible constitutional limits or whether it was exercised in a manner
constituting grave abuse of discretion. The SC ruled that GMA has validly declared PP 1017
for the Constitution grants the President, as Commander-in-Chief, a sequence of
graduated powers. From the most to the least benign, these are: the calling-out power, the
power to suspend the privilege of the writ of habeas corpus, and the power to declare
Martial Law. The only criterion for the exercise of the calling-out power is that whenever it
becomes necessary, the President may call the armed forces to prevent or suppress
lawless violence, invasion or rebellion. And such criterion has been met.
Resolution by the SC on the Take Care Doctrine
Pursuant to the 2nd sentence of Sec 17, Art 7 of the Constitution (He shall ensure that the
laws be faithfully executed.) the president declared PP 1017. David et al averred that PP
1017 however violated Sec 1, Art 6 of the Constitution for it arrogated legislative power to
the President. Such power is vested in Congress. They assail the clause to enforce
obedience to all the laws and to all decrees, orders and regulations promulgated by me
personally or upon my direction. The SC noted that such provision is similar to the power
that granted former President Marcos legislative powers (as provided in PP 1081). The SC
ruled that the assailed PP 1017 is unconstitutional insofar as it grants GMA the authority to
promulgate decrees. Legislative power is peculiarly within the province of the
Legislature. Sec 1, Article 6 categorically states that [t]he legislative power shall be vested
in the Congress of the Philippines which shall consist of a Senate and a House of
Representatives. To be sure, neither Martial Law nor a state of rebellion nor a state of
emergency can justify GMA[s exercise of legislative power by issuing decrees. The
president can only take care of the carrying out of laws but cannot create or enact laws.
Resolution by the SC on the Take Over Power Doctrine
The president cannot validly order the taking over of private corporations or institutions
such as the Daily Tribune without any authority from Congress. On the other hand, the
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19

word emergency contemplated in the constitution is not limited to natural calamities but
rather it also includes rebellion. The SC made a distinction; the president can declare the
state of national emergency but her exercise of emergency powers does not come
automatically after it for such exercise needs authority from Congress. The authority from
Congress must be based on the following:
(1) There must be a war or other emergency.
(2) The delegation must be for a limited period only.
(3) The delegation must be subject to such restrictions as the Congress may
prescribe.
(4) The emergency powers must be exercised to carry out a national policy declared
by Congress.
Resolution by the SC on the Issue that PP 1017 is a Martial Law Declaration
The SC ruled that PP 1017 is not a Martial Law declaration and is not tantamount to it. It is
a valid exercise of the calling out power of the president by the president.
H. Suspension of the Privilege of Writ of Habeas Corpus

Must be read in conjunction with Article III, Sec. 15 which states:

o The privilege of the writ of habeas corpus shall not be suspended except in
cases of invasion or rebellion, when the public safety requires it.
Habeas Corpus
o Writ directed to the person detaining another, commanding him to produce
the body of the prisoner at a designated time and place, with the day and
cause of his caption and detention, to do, to submit to, and receive whatever
the court or judge awarding the writ shall consider in his behalf
o Suspension is NOT the writ itself but only its privilege.
o Duration: not to exceed sixty (60) days, following which it shall be lifted,
unless extended by the Congress.
Effects of Suspension:
o Proclamation does NOT affect the right to bail
o Suspension applies only to persons facing charges of rebellion or offenses
inherent in or directly connected with invasion.
o Persons arrested must be charged within 3 days: if not, they must be
released
o Proclamation does not supersede civilian authority

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I. Martial Law
Martial Law Defined
In its strict sense, it refers to that law which has application when civil authority calls upon
the military arm to aid it in its civil function. Military arm does not supersede civil
authority.
A State of Martial Law DOES NOT:

Suspend the operation of the Constitution

Supplant the functioning of the civil courts and the legislative assemblies
Confer jurisdiction upon the military courts and agencies over civilians, where civil
courts are able to function
o Open Court Doctrine civilians cannot be tried by military courts if the civil
courts are open and functioning
Automatically suspend the privilege of the writ of habeas corpus

Important Notes on Martial Law:

Grounds for declaration: existence of invasion or rebellion when the public safety
requires it
Duration of such suspension or proclamation shall NOT exceed 60 days, following
which it shall be automatically lifted
Within 48 hours after such suspension or proclamation, the President shall
personally or in writing report his action to the Congress. If not in session, the
Congress must convene within 24 hours without need of a call.
Congress may, by majority of all its members voting jointly, revoke his acion.
Revocation may not be set aside by the President
By the same vote and in the same manner, the Congress may, upon initiative of the
President, extend his suspension or proclamation for a period to be determined by
the Congress if the invasion or rebellion shall continue and the public safety
requires the extension.
Action of President and Congress shall be subject to review by the Supreme Court
which shall have the authority to determine the sufficiency of the factual basis of
action. This matter is NO LONGER considered a political question and may be raised
in an appropriate proceeding by ANY citizen. Moreover, the SC must decide the
challenge within 30 days from the time it is filed.

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VII.

Pardoning Power

Const. Art. VII, Sec. 19:

Except in cases of impeachment, or as otherwise provided in this
Constitution, the President may grant reprieves, commutations, and pardons,
and remit fines and forfeitures, after conviction by final judgment.
He shall also have the power to grant amnesty with the concurrence of a
majority of all the Members of the Congress.
Executive Clemency

Granted for the purpose of relieving the harshness of the law or correcting mistakes
in the administration of justice
Exercise is discretionary upon the President and may not be controlled by the
legislature or reversed by courts, save only when it contravenes the limitations
discussed below.
It does NOT distinguish between criminal and administrative cases.
The power of executive clemency is non-delegable power and must be exercised by
the President personally.

Forms of Executive Clemency

Pardon
Act of grace which
exempts the
individual on whom
it is bestowed from
the punishment
which the law
inflicts for the crime
he has committed

Powers of the President

Commutation
Reduction or
mitigation of the
penalty

Reprieve
Merely a
postponement of a
sentence to a date
certain, or a stay of
execution.

Remission of Fines
and Forfeiture
Merely prevents the
collection of fines or
the confiscation of
forfeited property
CANNOT have the
effect of returning
property which has
been vested in third
parties or money
22

already in public
treasury

Limitations of Executive Clemency

1. Cannot be granted in cases of impeachment.
2. Cannot be granted in violation of any election law, rule or regulation without the
favorable recommendation of the Commission on Elections
3. Can be granted only after conviction by final judgment (except amnesty)
4. Cannot be granted in cases of legislative contempt or civil contempt
5. Cannot absolve convict of civil liability
6. Cannot restore public officers forfeited
Monsanto vs. Factoran [170 SCRA 190 (1989)]
Facts:
Monsanto was the Asst Treasurer of Calbayug City. She was charged for thecrime
of Estafa through Falsification of Public Documents. She was found guilty and was
sentenced to jail. She was however granted pardon by Marcos. She then wrote a
letter to the Minister of Finance for her to be reinstated to her former position since
it was still vacant. She was also requesting for back pays. The Minister of Finance
referred the issue to the Office of the President and Factoran denied Monsantos
request averring that Monsanto must first seek appointment and that the pardon
does not reinstate her former position. Also, Monsanto avers that by reason of the
pardon, she should no longer be compelled to answer for the civil liabilities brought
about by her acts.
Issue:
Whether or not Monsanto should be reinstated to her former post.
Held:
A pardon looks to the future. It is not retrospective. It makes no amends for the past.
It affords no relief for what has been suffered by the offender. It does not impose
upon the government any obligation to make reparation for what has been suffered.
Since the offense has been established by judicial proceedings, that which has been
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23

done or suffered while they were in force is presumed to have been rightfully done
and justly suffered, and no satisfaction for it can be required. This would explain
why petitioner, though pardoned, cannot be entitled to receive backpay for lost
earnings and benefits. On the other hand, civil liability arising from crime is
governed by the RPC. It subsists notwithstanding service of sentence, or for any
reason the sentence is not served by pardon, amnesty or commutation of sentence.
Petitioners civil liability may only be extinguished by the same causes recognized in
the Civil Code, namely: payment, loss of the thing due, remission of the debt, merger
of the rights of creditor and debtor, compensation and novation.
7. A grant of amnesty must be with the concurrence of a majority of all the Members of
the Congress
Classifications as to Effect
1. Plenary extinguishes all the penalties imposed including accessory disabilities
2. Partial does not extinguish all
Classification as to Presence of Condition
1. Conditional Pardon in the nature of a contract between the Chief Executive and the
convicted criminal; by the pardonees consent to the terms stipulated in the
contract, the pardonee has placed himself under the supervision of the Chief
Executive or his delegate who is duty bound to see to it that the pardonee complies
with the conditions of the pardon.
o Offender has the right to reject it
2. Absolute Pardon does not impose any condition upon the pardonee and is
complete even without the necessity of acceptance.
Effects:
Legal effect of a pardon is to restore not only the offenders liberty but also his civil
and political rights.
Pardon

Pardonee whose sentence is

condoned, is subject only to
reinstatement in cases of violation

Powers of the President

Parole

Release of the convict from

imprisonment but not a restoration
of his liberty
24

of the condition that may have been

attaced to the pardon.

Parole

Parolee is still in the custody of the

law although no longer under
confinement

Probation

Executive
Presupposes the prior service of
the part of the sentence

Judicial
May be granted even before actual
service of sentence

Amnesty

Granted by the President only with the concurrence by a majority of all the
members of the Congress
Requires a previous admission of guilt since a person would not need the benefit of
amnesty unless he were, to begin with, guilty of the offense covered by the
proclamation.
Amnesty commonly denotes a general pardon to rebels for their treason or other
high political offenses, or the forgiveness which one sovereign grants to the subjects
of another, who have offended, by some breach, the law of nations. Amnesty looks
backward, and abolishes and puts into oblivion, the offense itself; it so overlooks and
obliterates the offense with which he is charged, that the person released by amnesty
stands before the law precisely as though he had committed no offense.

Amnesty

Pardon

Extent

Political Offenses

Infraction of peace/common
crimes

Coverage

Granted to classes of persons

Granted to individuals

Approval of
Congress

Requires concurrence of
Congress

Does not require concurrence of

Congress

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25

Nature

Public act to which court may

take judicial notice

Private act which must be

pleaded and proved

Effectivity

Looks backward and puts into

oblivion the offense itself

Looks forward and relieves the

pardonee of the consequence of
the offense

Limitation

May be granted even BEFORE

trial

Can be granted only AFTER

conviction

VIII. Borrowing Power

Const. Art. VII, Sec. 20:
The President may contract or guarantee foreign loans on behalf of the
Republic of the Philippines with the prior concurrence of the Monetary
Board, and subject to such limitations as may be provided by law. The
Monetary Board shall, within thirty days from the end of every quarter of the
calendar year, submit to the Congress a complete report of its decision on
applications for loans to be contracted or guaranteed by the Government or
government-owned and controlled corporations which would have the effect
of increasing the foreign debt, and containing other matters as may be
provided by law.
Power to contract or guarantee foreign loans
The following are the requirements for the President may contract or guarantee foreign
loans on behalf of the Republic of the Philippines:
1. With prior concurrence of the Monetary Board
Reason for concurrence: The President may be tempted to contract or
guarantee loans to subsidize his program of government and leave it to
succeeding administration. Also, it will enable foreign lending institutions
(e.g. World Bank, International Monetary Fund) to impose conditions on
loans that might impair economic and political independence.
Why the Monetary Board (MB)? Because the MB has expertise and
consistency to perform the mandate since such expertise or consistency may
be absent among the Members of Congress.
Concurrence of MB does not diminish the executive nature of the power
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26

2. Subject to such limitations as may be provided by law

Monetary Board

Per R.A. No. 7653 or The New Central Bank Act, the Monetary Board exercises the
powers and functions of the Bangko Sentral. It is composed of seven (7) members
appointed by the President of the Philippines for a term of six (6) years.

Duty: It shall submit to Congress a complete report on loans within 30 days from the
end of every quarter to allow the Congress to act on whatever legislation may be
needed to protect public interest.

IX.

Diplomatic Power

The President, as Head of State, is supposed to be the spokesman of the nation on external
affairs. The conduct of external affairs is executive altogether. The foreign relations powers
include:
1. Power to negotiate treaties and international agreements
2. Power to appoint ambassadors and other public ministers and consuls
3. Power to receive ambassadors and other public ministers accredited to the
Philippines
4. Power to contract or guarantee foreign loans on behalf of the Republic
5. Power to deport aliens
6. Power to decide that a diplomatic officer who has become persona non grata be
recalled
7. Power to recognize government and withdraw recognition

When Concurrence of Senate Needed

Const. Art. VII, Sec. 21:

No treaty or international agreement shall be valid and effective unless
concurred in by at least two-thirds of all the Members of the Senate.
This provision lays down the general rule on treaties or international agreements and
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27

applies to any form of treaty with a wide variety of subject matter. All treaties or
international agreements entered into by the Philippines, regardless of subject matter,
coverage, or particular designation or appellation, requires the concurrence of at least 2/3
of all the Members of Senate to be valid and effective.
When Concurrence of Senate Not Needed
Less formal types of international agreements; Agreements which are temporary or are
mere implementations of treaties and statutes do not need concurrence.
Scope of Power to Concur
It should be emphasized that under our Constitution, the power to ratify is vested in the
President, subject to the concurrence of the Senate. The role of the Senate, however, is
limited only to giving or withholding its consent, or concurrence, to the ratification. Hence,
it is within the authority of the President to refuse to submit a treaty to the Senate or,
having secured its consent for its ratification, refuse to ratify it. Although the refusal of a
state to ratify a treaty which has been signed in its behalf is a serious step that should not
be taken lightly, such decision is within the competence of the President alone, which
cannot be encroached by this Court via a writ of mandamus. (Pimentel vs. Executive
Secretary, GR No. 158088, July 16, 2008)
Treaty vs. Executive Agreements

Treaty
International agreements which involve
political issues or changes of national
policy and those of permanent character

In treaties, formal documents require

ratification

Executive Agreement
International agreements involving
adjustment of details carrying out well
established national policies and
traditions and involving arrangements of
a more or less temporary nature
Binding through executive action (can be
concluded by the President alone
without the necessity of Senate
concurrence)

Pimentel v. Executive Secretary (GR No. 158088, July 6, 2005)

Facts:

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28

The petitioners filed a petition for mandamus to compel the Office of the Executive
Secretary and the Department of Foreign Affairs to transmit the signed copy of the Rome
Statute of the International Criminal Court (ICC) to the Senate of the Philippines for its
concurrence pursuant to Sec. 21, Art VII of the 1987 Constitution. The Rome Statute
established the ICC will have jurisdiction over the most serious crimes as genocide, crimes
against humanity, war crimes and crimes of aggression as defined by the Statute.
It is the theory of the petitioners that ratification of a treaty, under both domestic law and
international law, is a function of the Senate. Hence, it is the duty of the executive
department to transmit the signed copy of the Rome Statute to the Senate to allow it to
exercise its discretion with respect to ratification of treaties.
Moreover, petitioners submit that the Philippines has a ministerial duty to ratify the Rome
Statute under treaty law and customary international law. Petitioners invoke the Vienna
Convention on the Law of Treaties enjoining the states to refrain from acts which would
defeat the object and purpose of a treaty when they have signed the treaty prior to
ratification unless they have made their intention clear not to become parties to the treaty.
Issue:
Whether or not the Executive Secretary and the DFA have the ministerial duty to transmit
to the Senate the copy of the Rome Statute signed by a member of the Philippine mission to
the U.N. even without the signature of the President
Held:
No. The President as the head of state is the sole organ and authorized in the external
relations and he is also the country's sole representative with foreign nations. As the chief
architect of foreign policy, he is the mouthpiece with respect to the country's foreign
affairs. In treaty-making, the President has the sole authority to negotiate with other states
and enter into treaties but this power is limited by the Constitution with the 2/3 required
vote of all the members of the Senate for the treaty to be valid (Sec. 21, Art VII).
Furthermore, the legislative branch part is essential to provide a check on the executive in
the field of foreign relations, to ensure the nation's pursuit of political maturity and growth.

Petitioners further arguments equate the signing of the treaty by the Philippine
representative with ratification. It should be underscored that the signing of the treaty and
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29

the ratification are two separate and distinct steps in the treaty-making process. Note that
the signature is primarily intended as a means of authenticating the instrument and as a
symbol of the good faith of the parties. It is usually performed by the states authorized
representative in the diplomatic mission. Ratification, on the other hand, is the formal act
by which a state confirms and accepts the provisions of a treaty concluded by its
representative.
It should be emphasized that under our Constitution, the power to ratify is vested in the
President, subject to the concurrence of the Senate. The role of the Senate, however, is
limited only to giving or withholding its consent, or concurrence, to the ratification. Hence,
it is within the authority of the President to refuse to submit a treaty to the Senate or,
having secured its consent for its ratification, refuse to ratify it. Although the refusal of a
state to ratify a treaty which has been signed in its behalf is a serious step that should not
be taken lightly, such decision is within the competence of the President alone, which
cannot be encroached by this Court via a writ of mandamus.

X.

Budgetary Power
Const. Art. VII, Sec. 22:
The President shall submit to the Congress within 30 days from the opening
of every regular session, as the basis of the general appropriations bill, a
budget of expenditures and sources of financing, including receipts from
existing and proposed revenue measures.

The President, as chief administrator and enforcer of laws, is properly entrusted with such
power because he is in the best position to determine the needs of the government and
propose the corresponding appropriations on the basis of existing or expected revenues.
Budget and Budgetary Process
The budget of receipts and expenditures prepared by the Department of Budget and
Management and approved by the President is the basis for the general appropriation bill
passed by the Congress. The budgetary process consists of four (4) major phases namely:
1. Budget Preparation
2. Legislative Authorization*
3. Budget Execution
Powers of the President

30

4. Budget Accountability
*Note: The Congress may not increase the appropriations recommended by the President
for the operation of the Government as specified in the budget (Sec. 25 par. 1, Article VI).

XI.

Informing Power
Const. Art. VII, Sec. 23:
The President shall address the Congress at the opening of its regular
session. He may also appear before it at any other time.

Although couched in mandatory language, the first sentence of the provision does not
as a rule impose a compellable duty on the President.
Such information may be needed as basis of legislation.
The informing power is usually discharged through State of the Nation Address (SONA)
of the President which is delivered at the opening of the regular session of the
legislature.

XII.

Residual Power

Executive Order No. 292, Book III, Section 20:

Residual Powers. - Unless Congress provides otherwise, the President shall
exercise such other powers and functions vested in the President which are
provided for under the laws and which are not specifically enumerated
above, or which are not delegated by the President in accordance with law.
Whatever power inherent in the government that is neither legislative nor judicial has to
be executive (Marcos vs. Manglapus, GR No. 88211, September 15, 1989). Thus, whatever
is not judicial, whatever is not executive is the residual power exercised by the President.
The powers of the President are more than the sum of the enumerated executive powers.
The duty of the government to serve and protect the people as well as to see the
maintenance of peace and order, the protection of life, liberty and property and the
promotion of general welfare is the basis of the existence of residual unstated power
(Marcos vs. Manglapus, GR No. 88211, October 27, 1989).

Powers of the President

31

XIII.
A.
B.
C.
D.
E.
F.

Other Powers

Call Congress to a special session (Art. VI, Sec. 15)

Approve or veto bills (Art. VI, Sec. 27)
Deport aliens
Consent to deputization of government personnel by COMELEC
[Art. IX-C, Sec. 2(8)]
Discipline such deputies [Art. IX-C, Sec. 2 (8)]
By delegation from Congress, exercise emergency* [Art. VI, Sec. 23 (2)], and tariff
powers [Art. VI, Sec. 28 (2)]

*Conditions for the exercise of emergency powers:

There must be a war or national emergency
There must be a law authorizing the President to exercise such emergency
powers
Exercise must be for a limited period
Must be subject to restrictions that Congress may provide
Exercise must be necessary and proper to carry out a declared national policy
G.

Power to classify or reclassify lands

Powers of the President

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References
Bernas, Joaquin. (2003). The 1987 Philippine Constitution: A Commentary, 2003 ed.
Manila: Rex Bookstore Inc.
Cruz, Isagani & Cruz, Carlo. (2014). Philippine Political Law, 2014 ed. Quezon City: Central
Book Supply Inc.
San Beda Law Memory Aid 2014

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