ADMINISTRATIVE AND ELECTION LAWS

PRELIMS REVIEWER
Based on:

Philippine Administrative Law (Cruz, 2016)

Outline Reviewer in Political Law (Nachura, 2016)

ADMINISTRATIVE LAW
De ned

- branch of modern law under which the executive department of the government, acting in a quasi-
legislative or quasi-judicial capacity, interferes with the conduct of the individual for the purpose of
promoting the well-being of the community, as under the laws regulating public interest, professions,
trades and callings, rates and prices, laws for the protection of public health and safety, and the
promotion of public convenience.

- branch of public law which xes the organization of the government and determines the competence
of the authorities who execute the law and indicates to the individual remedies for the violation of his
rights.

Sources

1. Constitutional or statutory enactments creating administrative bodies

2. Decisions of courts interpreting the charters of administrative bodies and de ning their powers,
rights, inhibitions, among others, and the e ects of their determinations and regulations.

3. Rules and regulations issued by the administrative bodies in pursuance of the purpose for which
they were created.

4. Determinations and orders of the administrative bodies in the settlement of controversies arising in
their respective elds.

Administration De ned

As an institution As a function

The aggregate of individuals in whose hands the The actual running of the government by the
reins of government are for the time being. executive authorities through the enforcement of
laws and the implementation of policies.

The persons running the government during their Any activity outside of legislation and the
prescribed terms of o ce. rendering of judicial decisions will come under
administration.

Internal administration External administration

Rules de ning the relations of public functionaries De nes the relations of the public o cer with the
inter se and embraces the whole range of the law public in general.
of public o cers.

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 These include: rules by particular agencies or
o ces relating to work assignments, procedures
Rules promulgated are for observance by those
who have dealings or transactions with said
o ces. These are promulgated in the exercise of
its quasi-legislative authority for the regulation of
speci c matters placed under its jurisdiction.

Administration Government Law

Comprises the aggregate of
individuals in whose hands the
reins of government are for the
time being involving the actual
running of the government by
the executive authorities through
the enforcement of laws and the
implementation of policies.
Government refers to the agency
or instrumentality through which
the will of the State is
formulated, expressed, and
realized.
The impersonal command
provided with sanctions to be
applied in case of violation. It is
concerned only with obedience
to its mandate and not with the
circumstances or excuses of the
violator

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 ADMINISTRATIVE BODIES AND AGENCIES

De ned

- a body endowed with quasi-legislative and quasi-judicial powers for the purpose of enabling it to
carry out laws entrusted to it for enforcement or execution.

- Organ of the government, other than a court and other than a legislature, which a ects the rights of
private parties either through adjudication or rule-making.

Nature

- regarded as an arm of the legislature insofar as it is authorized to promulgate rules that have the force
of law by virtue of a valid delegation of legislative power.

- Loosely considered a court because it performs functions of a particular judicial character, as when it
decides factual and sometimes even legal questions as an incident of its general power of regulation.

- Note however, that administrative bodies endowed with quasi-judicial prerogatives are essentially
executive agencies, and are not to be considered as courts, or do not form part of the judiciary.

Categories of administrative relationships

1. Supervision and control

2. Administrative supervision

3. Attachment

Term De nition Source

Any department, bureau, o ce, commission, authority or

o cer of the National Government authorized by law or
executive order to make rules, issue licenses, grant
rights or privileges and adjudicate case; research
institutions with respect to licensing functions;
government corporations with respect to functions Administrative
regulating private right, privilege, occupation or Code of 1987,
Agency
business; and o cials in the exercise of disciplinary Book VII, Chapter
power as provided by law.
1, Sec. 2(1)

Any of the various units of the Government, including a

department, bureau o ce, instrumentality, or
government-owned or controlled corporation, or a local
government or a distinct unit therein.

Any agency of the National Government not integrated

within the department framework, vested with special
Government functions or jurisdictions by law, endowed with some if Malaga v
instrumentality not all corporate powers, administering special funds, Penachos, Jr
and enjoying operational autonomy, usually through a
charter.

Any agency organized or operating under a special

Malaga v
Chartered institution charter, and vested by law with functions relation to
Penachos, Jr
speci c constitutional polices or objectives

Department Executive department created by law

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 Bureau Any principal subdivision of any department

Any major functional unit of a department or bureau,

including regional o ces

O ce
Any position held or occupied by individual persons,
whose functions are de ned by law or regulation.

Any o the various units of the Government of the

Republic of the Philippines, including a department,
Government agency bureau, o ce, instrumentality or government-owned or
controlled corporation, or a local government or a
distinct unit.

Agency organized as a stock or non-stock corporation,

vested with functions relating to public needs whether
governmental or proprietary in nature, and owned by the
Government-owned
Government of the Republic of the Philippines directly or
or controlled
through its instrumentalities either wholly or, where
corporation
applicable as in the case of stock corporations, to the
extent of at least a majority of its outstanding capital
stock.

Financial institutions or corporations in which the

Government
government directly or indirectly owns majority of the
Financial Institutitons
capital stock.

Instrumentalities or agencies of the government, which

Government are neither corporations nor agencies integrated within
Instrumentalities with the departmental framework, but vested by law with
Corporate Powers / special functions or jurisdiction, endowed with some if
Government not all corporate powers, administering special funds,
Corporate Entities and enjoying operational autonomy usually through a
charter.

Composed of persons who are, at the outset, or at least

Administrative
eventually, experts in the particular eld of specialization Humphrey v US
agency
under its jurisdiction.

Attached agency

- larger measure of independence from the Department to which it is attached than one which is under
departmental supervision and control or administrative supervision.

Reason:
- attachment is merely for policy and program coordination. The independence of an attached
agency from departmental control and supervision is further reinforced by the fact that even an
agency is free from Departmental interference with respect to appointments and other personnel
actions in accordance with the decentralization of personnel functions under the Administrative Code
of 1987.

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 CREATION, ORGANIZATION, ABOLITION OF ADMINISTRATIVE AGENCIES

Ervin Analysis:

As a rule, an administrative agency owes its existence to the law creating it. Thus, its reorganization or
abolition likewise depends on the law to which it was established.

Creation Reorganization Abolition

Through Constitutional Through Constitutional

By the Constitution
amendment amendment

Through amendment of the

charter or repealing of the
charter.

Through the law which created it

By a statute or through another law
Note: the abolition is justi ed if
authorizing its reorganization
made in good faith and not
attended by grave abuse of
discretion.

The President has the power to

reorganize the o ces and
agencies in the executive
department in line with his
constitutionally granted power of
control over executive o ces
and by virtue of previous
delegation of the legislative
power to reorganize executive
o cers under existing statutes.

Types of administrative agencies

These are the ones:

1.    O ering some gratuity, grant or special privilege;

2.    Seeking to carry on certain of the actual business of government;

3.    Performing some business service for the public;

4.    Regulating business a ecting public interest;

5.    Regulating private business and individuals;

6.    Adjusting individual controversies because of a strong social policy involved;

7.    Making the government a private party


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 POWERS OF ADMINISTRATIVE AGENCIES

As a rule, administrative agencies has only such powers as are expressly granted to it by law or those
that are necessarily implied in the exercise of its implied powers.

QUASI-LEGISLATIVE POWER

De nition

- permits the body to promulgate rules intended to carry out the provisions of particular laws

- Rule-making power. The power to make rules and regulations which results in delegated legislation
that is within the con nes of the granting statute and the doctrine of non-delegability and separability
of powers.

- Authority delegated by the law-making body to the administrative body to adopt rules and regulations
intended to carry out the provisions of a law and implement legislative policy.

Doctrines on e ectivity and limitations of issuances of administrative regulations

E ectivity Limitation

Rules and regulations issued by administrative or Administrative agencies are not authorized to
executive o cers pursuant to the procedure or substitute their own judgment for any applicable
authority conferred by law upon the administrative law or administrative regulation with the wisdom
agency have the force and e ect, or partake of or propriety of which they do not agree, at least,
the nature, of a statue.
not before such law or regulation is set aside by
the authorized agency of government as
Reason:
unconstitutional or illegal and void. [Eslao v COA]

Expresses the policies, purposes, objectives,

remedies and sanctions intended by the
legislature in general terms.

Administrative regulations and policies enacted by

administrative bodies to interpret the law which
they are entrusted to enforce, have the force of
law, and are entitled to great respect.

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 Kinds of Administrative Regulations

Regulation De nition Legal E ect

Those which purport to do no more than interpret

the statute being administered to say what it
means. It is issued by the administrative body as
an incident of its power to enforce the law and is
intended merely to clarify its provisions for proper
observance by the people.
Merely persuasive and is
received by courts with
The administrative agency merely anticipates what much respect with
Interpretative rules
must be done by the courts. They are performing a presumption of legality
or regulations
judicial function rather than a legislative function, but not nality.

and interpretative regulations have validity in

judicial proceedings to that the extent they Merely advisory.
correctly construe the statute.

If an agency renders an opinion or a statement of

policy, it merely interprets a pre-existing law.

Designed to implement a primary legislation by

providing the details. It is issued by the
administrative body pursuant to a valid delegation
of legislative power and is intended to have binding
force and e ect of a law enacted by the legislature It has binding force and
Legislative rules or itself.
e ect of a law enacted by
regulations the legislature itself.

It is the act of administrative agencies in a

legislative capacity to supplement the statute, ll in
the details, or making the law, and usually act
pursuant to a speci c delegation of legislative
power.

CLASSIFICATION OF LEGISLATIVE RULES OR REGULATIONS

Intended to ll in the details of the law and to make

explicit what is only general. It seeks to enlarge
Supplementary
upon a statute, subject only to the standards xed
regulation
therein, to ensure its e ective enforcement in
accordance with the legislative will.

Issued upon the happening of a certain

contingency which the administrative body is given For purposes of
the discretion to determine or to ascertain, under ascertaining the
and pursuant to the law, some circumstances on existence of particular
Contingent
which the law, by its own terms, makes its own contingencies and on the
regulation
action depends, or to nd the facts or conditions bases thereof enforce or
properly prescribed under which a law as passed suspend the operation of
will or will not operate, that is, for putting in e ect, a law.
applying or suspending a law.

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 Administrative rule

- any agency statement of general applicability that implements or interprets a law, xes and describes
the procedures in, or practice requirements of, an agency, including its regulations.

Sources of power to promulgate administrative regulations

It is derived from the legislature, by virtue of a valid delegation.

Tests of Delegation

Completeness test Su cient standard test

Requires that the law specify limits which are

Requires that the law must set forth therein the
su ciently determinate or determinable — the
policy to be executed, carried out or implemented
delegate must conform in the performance of his
by the delegate
functions.

Requires that the law must be complete in all its Requires that the law must specify the limits of the
terms and conditions when it leaves the legislature delegates authority, announce the legislative
so that when it reaches the delegate, it will have policy, and specify the conditions under which it is
nothing to do but enforce it. to be implemented.

Some su cient standards:

If there are gaps in the law that will prevent its

1. Public interests

enforcement, the delegated will have the

2. Simplicity, economy and e ciency

opportunity to repair the omission through the

3. Public welfare

exercise of the discretion to determine what the

law shall be which is essentially and exclusively
“May see t” is not a su cient standard since it
legislative
may be abused. [Ynot v IAC]

Requisites for validity of administrative regulations

GENERAL APPLICATION

1. Promulgation must be authorized by the legislature;

2. Within the scope of the authority given;

3. Promulgated in accordance with prescribed procedure [see Article 2 of the Civil Code]

4. Reasonable

ADDITIONAL REQUISITES FOR THOSE WITH PENAL SANCTIONS

1. The law itself must declare for punishment of the violation of an administrative rule or regulation

2. The law should de ne or x the penalty for the violation of the administrative rule or regulation

The Publication rule per Tañada v Tuvera

Publication must be in full or it is no publication at all since its purpose is to inform the public of the
contents of the law.

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 Powers of the President

Those powers and functions vested in the President which are provided for
Residual powers under the laws and which are not speci cally enumerated or which are not
delegated by the President in accordance with law.

It is concerned with the work of applying policies and enforcing orders as

determined by proper governmental organs. It enables the President to x a
Administrative power
uniform standard of administrative e ciency and check the o cial conduct
of his agents.

Power of an o cer to alter or modify or set aside what a subordinate o cer

Control had done in the performance of his duties and to substitute the judgment of
the former for the latter

Power of general supervision or the power of a superior o cer to see to it

that lower o cers perform their functions in accordance with law.

Power of mere oversight over an inferior body — it does not include any
restraining authority over such body. Supervising o cers merely see to it that
Supervision
the rules are followed, but does not lay down such rules, nor does have the
discretion to modify or replace them.

If the same are not followed, the work may be ordered be done or re-done to
conform to the prescribed rules.

Ordinance Powers of the President [Chapter 2, Book III of the Administrative Code of 1987]
Acts of the President which relate to particular aspects of governmental
operation in pursuance of his duties as administrative head.

Administrative orders
An ordinance issued by the President which relates to speci c aspects in the
administrative operation of government.

Acts of the President providing for rules of a general or permanent character

Executive Orders
in implementation or execution of constitutional or statuary powers

Acts of the President xing a date or declaring a status or condition of public

moment or interest, upon the existence of which the operation of a speci c
Proclamations
law or regulation is made to depend, and which shall have the force of an
executive order

Acts of the President on matters of administrative detail or of subordinate or

Memorandum Orders temporary interest which only concern a particular o cer or o ce of the
Government

Acts of the President on matters relating to internal administration which the

Memorandum President desires to bring to the attention of all or some of the departments,
Circulars agencies, bureaus or o ces of the Government, for information or
compliance.

General or Special Acts and commands of the President in his capacity as Commander-in-Chief
Orders of the Armed Forces of the Philippines.

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 Doctrinal Rules on Construction and Interpretation

1. The regulation should be read in harmony with the statute and not in violation of the authority
conferred on the administrative authorities

2. Statutes, including administration rules and regulations, operate prospectively only, unless the
legislative intent to the contrary is manifest by express terms or by necessary implication.

3. The intention of the authors must be sought and given e ect.

4. The interpretation given by the administrative body to its own rules, while not binding on the courts,
is received with much respect and will usually be followed except only where it is clearly arbitrary
and unreasonable.

5. Opinions of the Secretary of Justice are material in the construction of statutes in pare materia.

6. Interpretation given to a rule or regulation by those charged with its execution is entitled to the
greatest weight by the court construing such rule or regulation, and such interpretation will be
followed unless it appears to be clearly unreasonable or arbitrary.

7. Courts will set aside an executive interpretation if there is an error of law, abuse of power, lack of
jurisdiction or grave abuse of discretion clearly con icting with the letter and spirit of the law.
8. Administrative o cer may revoke, repeal or abrogate Thea its or previous rulings of his predecessor
in o ce.

Guidelines in resolving disputes concerning interpretation by an agency

1. Whether the delegation was valid

2. Whether the regulation was within the regulation

3. Whether it was a reasonable regulation under a due process test

Doctrine of respect for administrative or practical construction

This allows courts to refer to several factors which may be regarded as bases — factors leading the
courts to give the principle controlling weight in particular instances, or as independent rules in
themselves.

Respect due to the governmental agencies

Competence
charged with administration

Expertness Experience

Agency is the one which the legislature must rely

Informed judgment and the fact that they
to advise it as to the practical working out of the
frequently are the drafters of the law they interpret
statute

Practical application of the statute presented the agency with unique opportunity and experiences for
discovering de ciencies, inaccuracies, or improvements in the statute.

Enforcement
- the power of administrative agencies to enforce administrative regulations.

- This may be e ected through judicial actions: mandamus, injunction, sanctions.

- It also includes the power to issue opinions and rulings to enable the administrative agency to
properly execute said regulations.

Amendment or repeal
- Administrative regulations are subject to subsequent amendments or even repeal by the authorities
that promulgated them.

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 - Congress cannot interfere by requiring that these regulations must be rst approved by them before it
will be e ective and enforceable since it violates the principles of bicameralism and rule on
presentment.

- Thus, from the moment the law becomes e ective, any provisions of law that empowers Congress
or any of its members to play any role in the implementation or enforcement of the law violates the
principle of separation of powers and thus it is unconstitutional. [Abakada Guro Partylist v Purisima]

QUASI-JUDICIAL POWER

De ned
- it enables the administrative body to resolve, in a manner essentially judicial, factual and sometimes
even legal questions incidental to its primary power of enforcement of law.

- Power to hear and determine questions of fact to which the legislative policy is to apply and to decide
in accordance with the standards laid down by the law itself in enforcing and administering the same
law.

- This is is exercised when it performs in a judicial manner an which is essentially of an executive or

administrative nature, where the power to act in such manner is incidental to or reasonably necessary
for the performance of the executive or administrative duty entrusted to it.

- It is the action, discretion of o cers who are required to investigate facts, or ascertain the existence of
facts and draw conclusions from them as a basis for their o cial action, and to exercise discretion of
a judicial nature.

- Refers to the action, discretion, etc., of public administrative o cers or bodies, who are required to
investigate facts, or ascertain the existence of facts, hold hearings, and draw conclusions from them,
as a basis for their o cial action and to exercise discretion of a judicial nature.

Judicial function Quasi-judicial function Ministerial function

The action and discretion of

One which an o cer or tribunal
public administrative o cers or
The power to determine what performs in the context of a
bodies, which are required to
the law is and what the legal given set of facts, in a
investigate facts or ascertain the
rights of the parties are, and prescribed manner and without
existence of facts, hold hearings,
then undertakes to determine regard for the exercise of his/its
and draw conclusions from them
these questions and adjudicate own judgment upon the
as basis for their o cial action
upon the rights of the parties. propriety or impropriety of the
ad to exercise discretion f a
act done.
judicial nature.

The right to speedy disposition of cases — applicable

The Constitutional right to a speedy disposition of cases in to limited to the accused in criminal
proceedings but extends to all parties in all cases, including civil and administrative cases, and in all
proceedings, including judicial and quasi-judicial hearings. Any party to a case may demand expeditious
action on all o cials who are tasked with the administration of justice. [Lopez v O ce of the
Ombudsman]

Quasi-judicial body Quasi-judicial agency

The organ of government other than a court and One which performs adjudicatory functions such
other than a legislature which a ects the rights of that its awards determine the rights of parties, and
private parties through either adjudication or rule- their decisions have the same e ect as judgment
making. of a court.

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 Requisites for proper exercise of quasi-judicial power — CUMULATIVE CONCURRENCE

1. Jurisdiction must be properly acquired by the administrative body

N.B.: For doctrinal readings on jurisdiction, refer to pp. 126 to 149 of Cruz.

2. Due process must be observed in the conduct of the proceedings

Source

- incidental to the power of regulation vested in the administrative body but is often expressly conferred
by the legislature through speci c provisions in the charter of the agency.

- Generally, the quantum of judicial or quasi-judicial powers which an administrative agency may
exercise is de ned in the enabling act of such agency. The extent to which an administrative entity
may exercise such power depends largely, if not wholly, on the provisions of the statute creating or
empowering such agency.

Determinative powers and functions

Power De nition Examples

Enabling Permits the doing of an act which the 1. Issuance of licenses

law undertakes to regulate and which 2. Approval of articles of incorporation

would be unlawful without government 3. Allowing of public exhibition of movies

approval. 4. Issuance of authorities ti permit occupancy

of a newly-constructed building.

Directing Ordering the doing of performance of 1. Requiring of factories to use certain

particular acts to ensure compliance chemicals to protect the environment

with the law and are often exercised 2. Installation of safety devices on common
for corrective purposes carriers

3. Compelling of an employer to reinstate an

illegally dismissed employee and pay him
damages.

CLASSIFICATIONS OF DIRECTING POWERS

Dispensing Allows the administrative o ce to By analogy, a student excused from physical

relax the general operation of a law or education activities for health reasons.
exempt from the performance of a
general duty.

A power that is concomitant with its

authority to enforce laws, investigate
o ense, and prosecute those
committing the same.

Summary Refers to the use by administrative 1. Mayor’s act of padlocking lthy restaurants
authorities of force upon persons or or movie houses in favor of public
things without the necessity of decency.

previous judicial warrants. 2. Shooting of mad dog on the loose

3. Take-over of BSP of mismanaged banks.

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 Examining Enables it to inspect the records and Exercise of powers include:

premises, and investigate the 1. Issuance of subpoenas

activities, of persons or entities 2. Swearing in of witnesses

coming under its jurisdiction.

3. Interrogation of witnesses

4. Calling for production of books, papers

Allows many administrative agencies and records

to actually conduct hearings, issue 5. Requiring that books, papers and records
writs of preliminary injunction and even be made available for inspection

punish for contempt, in relation to its 6. Inspection of premises

broad power of investigation or 7. Requiring written answers to

examination. questionnaires

8. Requiring periodic or special reports

9. Requiring the ling of statements.

Doctrines on administrative agencies adopting their own Rules of Procedure

- administrative bodies are also vested with the implied power to prescribe the rules to be observed in
the conduct of its proceedings. It is justi ed under the doctrine of (necessary) implication.

- Where a statute does not require any particular method of pro endure to be followed by an
administrative agency, the agency may adopt any reasonable method to carry out its functions.
[Provident Tree Farms, Inc v Batario, Jr]

- Administrative rules of procedures are not strictly enforced in administrative disputes. They should be
construed liberally in order to promote their object and to assist the party’s in obtaining a just, speedy
and inexpensive determination of their respective claims and defenses. [Mangubat v De Castro]

- No denial of due process if the decision was rendered on the evidence presented at the hearing, or at
least contained in the record and disclosed to the parties a ected.

- Courts may not enlarge the scope of a statute and include situations not provided or intended by the
law maker. [Lapid v Court of Appeals]

Subpoena power

- it is not inherent in administrative bodies.

- They may only summon witnesses and require the production of evidence only when duly allowed by
law, and always only in connection with the matter they are authorized to investigate.

- Note that the fact that it may conduct investigations, it does not follow that it can also summon
witnesses and take testimony in the absence of a clear grant of this power from the legislature.
[Carmelo v Ramos]

Contempt power

- essentially judicial and cannot be claimed as an inherent right by the administrative body.

- It must be expressly conferred upon the body and, additionally, must be used only in connection with
its quasi-judicial as distinguished its purely administrative or routinely functions.

Right to notice and hearing

- essential to due process and its non-observance will invalidate administrative proceeds.

- The essence of due process in administrative proceedings is the opportunity to explain one’s side or a
chance to seek reconsideration of the action or ruling complained of. [Padilla v NLRC]

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 Exceptions to notice and hearing

1. Urgency of immediate action

2. Tentativeness of administrative action

3. The right had previously o ered but not claimed

4. Summary abatement of nuisance per se [acts which threatens public health and decency]

5. Preventive suspension of public servant facing administrative charges

6. Cancellation of passport of a person sought for criminal prosecution

7. Summary distraint and levy of the properties of a delinquent taxpayer

8. Replacement of a temporary or appointee.

Administrative due process

Requisite of administrative due process [Ang Tibay v CIR]

Right of the party interested or a ected to present

Right to a hearing
his own care and submit evidence in support

Right to adduce evidence, without the

Tribunal must consider evidence presented;

corresponding duty on the part of the board to

consider it.

Decision must have something to support itself;

A decision with absolutely nothing to support it is
a nullity

Substantial evidence — relevant evidence as a

Evidence must be substantial

reasonable mind might accept as adequate to

support a conclusion

Decision must be based on the evidence adduced

Con ning of evidence disclosed for purposes of
[at hearing or in the record and disclosed to the
determining a decision
party]

Board or judges must act on its or their

independent consideration of the facts and the
law of the case [not simply accepting the views of
a subordinate in arriving at a decision]

Decision rendered in a manner that the parties

know the various issues involved and the reason
for the decision rendered.

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