Monday, August 20, 2012

Bautista vs Salonga Case Digest


Here are some digested cases from the Jurisprudence regarding issues related to the Executive Department. I know, I digested it differently but this is how I remember things easily. You still have to read the whole Jurisprudence. You will never understand the things I wrote below, maybe some but perhaps most of the things I jot down are only the important ones and I might even forgot some important key factors, unless you have read the original text. Do not rely too much ion this. These digested cases will just help you remember things out during oral recitations. God bless future lawyers!


Bautista vs Salonga
GR No. 86439
April 13, 1989
Whether or not the appointment of Mary Concepcion Bautista as Chairman of the Commission on Human Rights (independent office) with no consent by the Commission of Appointments.
The president, realizing the need for a permanent chairman and members of CHR appointed Bautista. Bautista received a letter for submission in connection with the confirmation of her appointment.
Arguments of Bautista:
1.    Not subject to confirmation since it is an independent office
Arguments of Commission on Appointments:
1.    Disapproved Bautista as ad interim because of the refusal to submit to the jurisdiction
2.    Sec 6 Chapter II of Rules of Commission on Appointments – the denial for submission denied the motion for reconsideration
Rule of Court:
1.    CHR position of chairman not among the positions mentioned in the first sentence of Sec 16 Art VII
2.    Constitutional law is concerned with power not political convenience.
3.    There was no vacancy~ from temporary to permanent appointment
4.    Executive Order (163-A) only speaks of tenure in office which is at the pleasure of the President. Tenure means not be confused with term of office. Realization of how precious are rights could be. A chairman is not made by statute but by Constitution.
The removal must be for cause and with due process, Government of laws not for men.

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