Commission on Human Rights Employees’ Association (CHREA) vs. Commission on Human Rights (CHR), G.R. No. 155336, November 25, 2004
### Facts:
1. **February 14, 1998**: Congress enacted Republic Act No. 8522, the General Appropriations Act (GAA) of 1998, which included special provisions applicable to all constitutional offices enjoying fiscal autonomy.
2. **September 4, 1998**: The Commission on Human Rights (CHR) issued Resolution No. A98-047, implementing an upgrading and reclassification scheme among selected positions within the CHR.
– Proposed creation of ten additional plantilla positions.
3. **October 19, 1998**: CHR issued Resolution No. A98-055, providing for the upgrading of certain positions’ salary grades.
4. **November 17, 1998**: CHR issued Resolution No. A98-062, “collapsing” some positions to fund their staffing modifications.
5. **DBM Review**: The CHR submitted the scheme to the Department of Budget and Management (DBM) for approval, but it was denied by Secretary Benjamin Diokno.
– Cited that the scheme elevated field units and offices beyond permissible levels without legal basis.
6. **March 29, 1999**: CSC-National Capital Region recommended disapproval of the reclassification scheme following DBM’s rejection.
7. **December 16, 1999**: CHREA (petitioners) requested CSC-Central Office to affirm the rejection, but the CSC-Central Office denied it.
– Resolution No. 99-2800 denied CHREA’s request and upheld the CHR scheme.
8. **June 9, 2000**: CSC-Central Office denied CHREA’s motion for reconsideration.
9. **Court of Appeals**: CHREA elevated the dispute, but the Court of Appeals affirmed the CSC-Central Office decision.
10. **Supreme Court Petition**: CHREA petitioned the Supreme Court, challenging the validity of the upgrading and reclassification scheme introduced by the CHR.
### Issues:
1. **Fiscal Autonomy**: Whether the CHR is among the constitutional bodies enjoying fiscal autonomy, making its reclassification scheme valid without DBM’s approval.
2. **Salary Standardization Law**: Whether CHR’s reclassification scheme must conform to the Salary Standardization Law regardless of asserted fiscal autonomy.
### Court’s Decision:
1. **Fiscal Autonomy**:
– **The Court held that CHR does not enjoy full fiscal autonomy granted to Constitutional Commissions (Civil Service Commission, Commission on Elections, and Commission on Audit) and the Judiciary**. The Constitution only guarantees the automatic and regular release of CHR’s approved annual appropriations, not additional aspects of fiscal autonomy.
– **Interpretation**: After reviewing historical constitutional discussions, the Court found that CHR was meant to have automatically released appropriations, but this did not extend to other elements of fiscal autonomy such as reclassification or staff upgrading without DBM’s approval.
2. **Salary Standardization Law**:
– **Applying the Doctrine and Laws**: Despite CHR’s argued fiscal autonomy under special provisions, the Court found that CHR is still bound by the Salary Standardization Law which necessitates DBM’s approval for reclassification schemes.
– **DBM Authority**: The Court reiterated that DBM has sole authority in administering the unified compensation and position classification system. Therefore, the CHR must conform to the provisions of the Salary Standardization Law and could not autonomously reclassify or upgrade positions.
### Doctrine:
**Limited Fiscal Autonomy Doctrine**:
– CHR has a limited sense of fiscal autonomy restricted to the automatic and regular release of its approved annual appropriations. This does not extend to reclassification or creation of positions without DBM approval.
### Class Notes:
– **Key Elements**:
– *Distinction Between Fiscal Autonomy*: Judiciary and Constitutional Commissions enjoy broader fiscal autonomy, including self-determined allocation, utilization, and organizational restructuring within legal frameworks.
– *Application of Salary Standardization Law*: All government agencies, including those with fiscal autonomy, must conform to compensation standardization laws, with DBM as the authoritative body.
– **Legal Provisions**:
– *1987 Constitution, Art. XIII, Sec. 17(4)*: Specifies automatic and regular release of CHR appropriations but does not confer broader fiscal autonomy.
– *Republic Act No. 6758*: Establishes the Salary Standardization Law enforced by DBM.
– *General Appropriations Act, Special Provisions*: Though providing some organizational liberties, all actions are still subject to standardization laws enforced by DBM.
### Historical Background:
– **Context**:
– After the 1986 People Power Revolution, the 1987 Constitution aimed to stabilize democracy and enhance human rights protections, leading to the establishment of CHR.
– Fiscal autonomy was granted to key constitutional bodies to insulate them from political influences, but the scope varied among them.
– The CHR, while given some independence regarding budgetary matters, was not intended to have the same breadth of fiscal autonomy as other bodies like the Judiciary and major Constitutional Commissions.
This precedent ensures meticulous adherence to separation of fiscal powers and regulatory oversight within the Philippine government’s operational framework.
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