Panghulan, Ynigo B.

PA 105: Administrative Law

National College of Public Administration and Governance (NCPAG)
Professor: Atty. Adler Delloro
2021-68079
Case Digest 1 Activity

1. Ople vs. Torres, 293 SCRA 141 (G.R. No. 127685, July 23, 1998)

Issue: According to Petitioner Ople the Adaptation of a National Computerized

Identification Reference system is unconstitutional because it is 1.) a usurpation of the
Congress to legislate laws and 2.) invades the citizens' privacy. So the problem now in
this case is that is it constitutional for the president of the Philippines to authorize these
kinds of laws or unconstitutional.
Ruling: With the case on hand, the Supreme Court of the Philippines decided that the
implementation of the National Computerized Reference system is, therefore,
unconstitutional because it can violate the rights of citizens to protect their data and
privacy, and with the implementation of this, there might be complications that we may
not foresee in the future especially that the citizen’s data is on the line.
2. Eugenio v. CSC, 243 SCRA 196.
Issue: The issue was whether or not the Civil Service Commission can have the power
or authority to abolish the Career Executive Service Board. Also, the question lies in did
the CSC usurped the legislative powers of Congress when it abolished the CESB.
Ruling: The ruling of the Supreme Court of the Philippines is YES, the CSC usurped
the legislative powers of the Congress as they do not have such powers to decide on
the abolishment of CESB as it is law written under the Presidential Decree No. 1. The
power to abolish or make such decisions when it comes to laws or administrative offices
are only and should be decided by the legislative branch.
 3. Pichay, Jr. vs. Office of the Deputy of Executive Secretary for Legal
Affairs-Investigative and Adjudicatory Division, 677 SCRA 408 [G.R. No.
196425, July 24, 2012].

Issue: The petitioners are saying that there was no written law that could allow
the president to reorganize their office. In this scenario, the petitioners believe that
the president doesn't have the constitutional rights to implement the Investigative and
Adjudicatory Division, Office of the Deputy Executive Secretary for Legal Affairs
(IAD-ODESLA), and by creating an additional office that corresponds to quasi-judicial
responsibilities, the President will also usurp the powers of congress to create a public
office, giving the responsibility to appropriate funds and delegate quasi-judicial functions
to administrative agencies and also intrude one of the main function of the Office of the
Ombudsman. Also, EO 13 violates the guarantee of due process and the equal
protection clause.
Ruling: The Supreme Court answered that there is no usurpation of legislative
powers and powers of the Ombudsman in the implementation of IAD-ODESLA and
it doesnt have quasi-judicial functions and responsibilities but rather a fact-finding and
recommendatory body. Lastly, EO 13 did not breach the rights of petitioners on
due process and did not step on the equal protection of the laws. The petition was
then dismissed by the Supreme Court for the reason that the petitioner didn't have
enough evidence to support that the President of the Philippines’ Executive Order 13 is
an illegal exercise of power and thus didn’t have the evidence to say that the
Constitution was breached or violated in terms of reorganizing the office as what was
stated in the Executive Order 292.

4. Biraogo v. The Philippine Truth Commission of 2010, 637 SCRA 78 [G.R.

No. 192935 & G.R. No. 1963036. December 7, 2010]

Issue: The petitioners have questioned Executive Order 1 because according to them,
EO1 violates the following: 1.) The PTC is an avenue that usurps the powers of
Congress. Additionally, the lack of separation of powers because it is usurping the
powers of Congress in allocating funds to offices, agencies, and commissions.
2.) EO1 displaces the powers and responsibilities of the Ombudsman and the
Department of Justice (DOJ) and lastly 3.) it branches and violates the equal
protection clause of the Philippine Constitution.

Ruling: Although The Supreme Court acknowledged that the president has the
complete authority to make PTC or the truth commission and it was made clear that the
PTC will not scrape away the power, responsibilities, and functions of the Office of the
Ombudsman, the petitions were granted and the Executive Order 1 is considered
unconstitutional as the Supreme Court agreed that it violates the equal protection
clause of the Philippine Constitution.