Facts:

On the strength of RA No. 8522, or the General Appropriations Act of 1998, which authorizes Constitutional
Commissions and Offices to have fiscal autonomy and formulate and implement the organizational structures of their
respective offices, to fix and determine the salaries, and make adjustments in their personal services itemization
including the transfer of item or creation of new positions in their respective offices, the Commission on Human
Rights (CHR) promulgated Resolution No. A98-047 and Resolution No. A98-062 to  upgrade, reclassify, and create
positions in the Commission and to augment the commensurate amount generated from savings under Personnel
Services. CHR, a member of the Constitutional Fiscal Autonomy Group (CFAG), believes that they also have fiscal
autonomy. The CHR forwarded said staffing modification and upgrading scheme to the Department of Budget and
Management (DBM) with a request for its approval, but the then DBM secretary Benjamin Diokno denied the request
since some of the recommended upgrade change the context from support to substantive without actual change in
functions while those creating key positions are not authorized by the law or directed by the President.

The DBM's disapproval of the proposed personnel modification scheme was recommended by Civil Service
Commission (CSC-NCR) to its Central Office to which the officers of petitioner Commission on Human Rights
Employees' Association (CHREA), in representation of the rank and file employees of the CHR, requested the CSC-
Central Office to affirm. According to CHREA, only the DBM has the appropriate authority mandated by law to
evaluate and approve matters of reclassification and upgrading, as well as creation of positions. Respondent CHR
sharply retorts that CHREA has no locus standi considering that there exists no official written record in the
Commission recognizing petitioner as a bona fide organization of its employees nor is there anything in the records to
show that its president, Marcial A. Sanchez, Jr., has the authority to sue the CHR. 

Issue:

1. WN CHREA has locus standi or right to bring an action against CHR

2. WN the approval by the DBM is a condition precedent to the enactment of an upgrading, reclassification,
creation and collapsing of plantilla positions in the CHR
3. WN CHR has fiscal autonomy

Ruling:

1. Yes. CHREA has a locus standi since a proper party is one who has sustained or is in immediate danger of
sustaining an injury as a result of the act complained of. CHREA which consists of rank and file employees
of respondent CHR protests that the upgrading and collapsing of positions benefited only a select few in the
upper level positions in the Commission resulting to the demoralization of the rank and file employees. This
sufficiently meets the injury test. The CHR's upgrading scheme, if found to be valid, potentially entails eating
up the Commission's savings or that portion of its budgetary pie otherwise allocated for Personnel Services,
from which the benefits of the employees, including those in the rank and file, are derived.

2. Yes. Pursuant to Rep. Act No. 6758 or the Salary Standardization Law, the DBM shall establish and
administer a unified Compensation and Position Classification System, applicable to all positions, appointive
or elective, on full or part-time basis, now existing or hereafter created in the government, including
government-owned or controlled corporations and government financial institutions. The term "government"
here refers to the Executive, the Legislative and the Judicial Branches and the Constitutional Commissions.
Considering that it encompasses the entire gamut of government offices, sans qualification, CHR is
therefore not exempted. DBM has the right to control or regulate in behalf of matters of compensation and
that the approval of the DBM must first be sought prior to implementation of any reclassification or upgrading
of positions in government, including that of CHR’s.

3. No. The CHR, although a constitutional creation is not included in the genus of offices accorded fiscal
autonomy by constitutional or legislative fiat. In Blaquera v. Alcala and Bengzon v. Drilon, only the Judiciary,
the Civil Service Commission, the Commission on Audit, the Commission on Elections, and the Office of the
Ombudsman, enjoy fiscal autonomy. As envisioned in the Constitution, the fiscal autonomy enjoyed by said
offices contemplates a guarantee of full flexibility to allocate and utilize their resources with the wisdom and
dispatch that their needs require. It recognizes the power and authority to levy, assess and collect fees, fix
rates of compensation not exceeding the highest rates authorized by law for compensation and pay plans of
the government and allocate and disburse such sums as may be provided by law or prescribed by them in
the course of the discharge of their functions. CHR’s membership to the Constitutional Fiscal Autonomy
Group (CFAG) does not cloth it with fiscal autonomy. Fiscal autonomy is a constitutional grant, not a tag
obtainable by membership.