Antonio Noblejas V Claudio Teehankee

G.R No. 28790 ; April 29, 1968

Facts:

Teehankee as Secretary of Justice sent a le4er to Noblejas, the then

Commissioner of Land Registration, asking him why should he not be
subject to a disciplinary action for his approval or recommending approval
of subdivision plans which are in excess of the areas covered by the
original titles. Noblejas argued that only Supreme Court can issue a
disciplinary action upon his person since by virtue of RA 1151, the position
of Commissioner of Land Registration is entitled to the same
compensation, emoluments and privileges as that of a Judge of First
Instance. Afterwards, the Executive Secretary finally suspended Noblejas
hence this case. Noblejas elevated the issue to the Supreme Court,
contending that he should only be dealt with according to how a Judge of a
First Instance is being treated since accordingly he is entitled to the same
rights and privileges.

Issue:

Whether of not only the Supreme Court has the power to investigate
Noblejas as Commissioner of Land Registration by virtue of RA 1151.

Ruling:

No, Supreme Court ruled that they do not have the right to investigate
Noblejas as it would violate the doctrine of separation of powers. Supreme
Court pointed out that Sec. 67 of Judiciary Act provides that “District
Judge” cannot be remove by the President of the Philippines unless
sufficient cause shall exist in the judgement of the Supreme Court. No
particular provision of law does it entail that a Commissioner of Land
Registration is a District Judge or in fact a member of the Judiciary at all.
There are instances wherein the Legislature stated in a plain and
unequivocal language the manner of treatment on a certain specific officials
like for instance, Judges of Agrarian Relations which is to be removed in
the same manner as that of Judges of the Court of First Instance. Supreme
Court further ruled that if the Legislature intended those in the general
grant of privileges or rank and privileges of Judges of the Court of First
Instance be removed or suspended only upon the recommendation of the
Court, it would be unconstitutional as it would violate the fundamental
doctrine of separation of powers.