Control Power

The President shall have control of all the

executive departments, bureaus and offices. He shall
ensure that the laws be faithfully executed.
Control the power of an officer to alter or modify or
nullify or
set aside what a subordinate officer had done
in the performance of his duties and to
substitute the judgment of the former for that
of the latter.

Drilon v Lim (Control vs Supervision)

An officer in control lays down the rules in the doing of an act
Supervision does not cover such authority. The supervisor or superintendent
merly sees to it that the rules are followed, but he himself does not lay down
such rules, nor does he have the discretion to modify or replace them.
Doctrine of Qualified Political Agency all the different executive and
administrative organizations are alter egos of the Executive Department.
President has full control of all Cabinet members. He may
appoint them, shuffle them, replace them without any legal
inhibition since they are merely his alter ego
Not applicable to acts of cabinet secretaries done in their
capacity ex officio
Villena v Sec. of Interior (Doctrine of Qualified Political Agency)
Without minimizing the importance of heads of various departments, their
personality is a project of the President. Their acts performed and
promulgated are, unless disapproved by President, presumptively the acts of
the President.
Manubay v Garilao
A further appeal froma decision of a cabinet secretary may be taken to the
Office of the President before resorting to judicial action, to be consistent with
the Doctrine of Exhaustion of Administrative Remedies. (but this doctrine is
not necessary/required if there is a special law that provides for a different
mode of appeal)
Trade & Investment Development Corp v Manalang-Demigillo
Petitioner sought to justify its reorganization, as directed by its board of
directors, by invoking this doctrine, stating that since the members of its
board are cabinet secretaries, their act of providing for the reorganization
should be considered as act of President.
HELD: Although SC upheld the validity of the reorganization, it did so based
on other groumds, and not the doctrine of qualified political agency. Under
Sec 10 of PD 8494, gi list ang mga ex officio members Evidently, it was
the law, not the President, that sat them in the Board. Therefore, ex officio
Angeles v Gaite
SC upheld validity of memorandum circular issued by President, limiting his
review of resolutions, orders or adjudications of the Secretary of Justice to
offenses punishable by reclusion perpetua to death on the basis of the
doctrine of qualified political agency. Plus, President has not totally abdicated
his power of control as Memo Circular 58 allowas an appeal if the imposable

penalty is reclusion perpetua or higher. // It would be unreasonable to impose

upon the President the task of reviewing all preliminary investigations decide
by SoJ. To do so will unduly hamper his othe important duties.