COMMISSION ON HUMAN RIGHTS EMPLOYEES’ ASSOCIATION (CHREA) vs. COMMISSION ON HUMAN RIGHTS
G.R. No. 155336. November 25, 2004.
FACTS:
On 14 February 1998, Congress passed Republic Act No. 8522, otherwise
known as the General Appropriations Act of 1998. It provided for
Special Provisions Applicable to All Constitutional Offices Enjoying
Fiscal Autonomy. On the strength of these special provisions, the CHR
promulgated Resolution No. A98-047 adopting an upgrading and
reclassification scheme among selected positions in the Commission. To
support the implementation of such scheme, the CHR, in the same
resolution, authorized the augmentation of a commensurate amount
generated from savings under Personnel Services. By virtue of Resolution
No. A98-062 the CHR “collapsed” the vacant positions in the body to
provide additional source of funding for said staffing modification.
Among the positions collapsed were: one Attorney III, four Attorney IV,
one Chemist III, three Special Investigator I, one Clerk III, and one
Accounting Clerk II. The CHR forwarded said staffing modification and
upgrading scheme to the DBM with a request for its approval, but the
then DBM secretary Benjamin Diokno denied the request. In light of the
DBM’s disapproval of the proposed personnel modification scheme, the
CSC-National Capital Region Office, through a memorandum recommended to
the CSC-Central Office that the subject appointments be rejected owing
to the DBM’s disapproval of the plantilla reclassification. Meanwhile,
the officers of petitioner CHREA, in representation of the rank and file
employees of the CHR, requested the CSC-Central Office to affirm the
recommendation of the CSC-Regional Office. CHREA stood its ground in
saying that the DBM is the only agency with appropriate authority
mandated by law to evaluate and approve matters of reclassification and
upgrading, as well as creation of positions. The CSC-Central Office
denied CHREA’s request in a Resolution and reversed the recommendation
of the CSC-Regional Office that the upgrading scheme be censured.
ISSUE:
Whether or not the Commission on Human Rights validly implement an
upgrading, reclassification, creation, and collapsing of plantilla
positions in the Commission without the prior approval of the Department
of Budget and Management?
HELD:
CHREA grouses that the Court of Appeals and the CSC-Central Office both
erred in sanctioning the CHR’s alleged blanket authority to upgrade,
reclassify, and create positions inasmuch as the approval of the DBM
relative to such scheme is still indispensable. Petitioner bewails that
the CSC and the Court of Appeals erroneously assumed that CHR enjoys
fiscal autonomy insofar as financial matters are concerned, particularly
with regard to the upgrading and reclassification of positions therein.
The CHR, although admittedly a constitutional creation is, nonetheless,
not included in the genus of offices accorded fiscal autonomy by
constitutional or legislative fiat.as the law’s designated body to
implement and administer a unified compensation system, is beyond cavil.
The interpretation of an administrative government agency, which is
tasked to implement a statute is accorded great respect and ordinarily
controls the construction of the courts. In Energy Regulatory Board v.
Court of Appeals,we echoed the basic rule that the courts will not
interfere in matters which are addressed to the sound discretion of
government agencies entrusted with the regulation of activities coming
under the special technical knowledge and training of such agencies.