Adminstrative Case: CHREA vs CHR G.R. No. 155336. November 25, 2004.

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.


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