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MANILA ELECTRIC CO v. PASAY TRANSPORTATION CO. 1.

WON the Commissioner of Land Registration may only


FACTS: Petition is requesting the members of the SC, sitting be investigated by the Supreme Court, in view of the
as a board of arbitrators, to fix the terms upon which certain conferment upon him of the rank and privileges of a
transportation companies shall be permitted to use the Judge of the Court of First Instance. — NO.
Pasig bridge of the Manila Electric Company and the - Petitioner’s contention would make such grants of
compensation to be paid to the Manila Electric Company by privileges unconstitutional since it would violate the
such transportation companies, pursuant to Sec. 11 of Act fundamental doctrine of separation of powers, by
No. 1446, which provides that the terms on which other charging this court with the administrative function of
person or corporation shall use right of way, and the supervisory control over executive officials, and
compensation to be paid to the grantee by such other simultaneously reducing pro tanto the control of the
person or corporation for said use, shall be fixed by the Chief Executive over such officials, when the Constitution
members of the Supreme Court, sitting as a board of has expressly placed the power to discipline and remove
arbitrators, the decision of a majority of whom shall be administrative officials who are presidential appointees
final.” under the President’s control and supervision

ISSUE/S: IN RE: RODOLFO MANZANO


1. WON the members of the SC can sit as a board of FACTS: Manzano, an RTC Judge, sent a letter to the Court
arbitrators and act in that capacity. — NO requesting that he be authorised to accept his appointment
- The Supreme Court and its members should not and as a member of Ilocos Norte Provincial Committee on
cannot be required to exercise any power or to perform Justice, the functions of which are to receive complaints
any trust or to assume any duty not pertaining to or against any apprehending officers who may have
connected with the administering of judicial functions. committed abuse in their discharge of duties and
When the Organic Act speaks of the exercise of recommend revision of law or regulation which is
"jurisdiction" by the Supreme Court, it could not only prejudicial to administration of justice, and that his
mean the exercise of "jurisdiction" by the Supreme Court membership in the Committee not be considered as
acting as a court, and could hardly mean the exercise of violation of the independence of the judiciary.
"jurisdiction" by the members of the Supreme Court,
sitting as a board of arbitrators. ISSUE/S:
- Moreover, Congress cannot require or authorize the court 1. WON Manzano can accept the position. — NO
to exercise any other jurisdiction or power, or perform - The members of the Supreme Court and other courts
any other duty. established by law shag not be designated to any agency
performing quasi judicial or administrative functions
NOBLEJAS v. TEEHANKEE (Section 12, Art. VIII, Constitution). Administrative
FACTS: Noblejas is duly appointed as the commissioner of functions are those which involve the regulation and
land registration, a position created by RA No. 1151. Same control over the conduct and affairs of individuals for
law provides that commissioner is entitled to same their own welfare and the promulgation of rules and
compensation, emoluments and privileges as those of a regulations to better carry out the policy of the
Judge of the Court of First Instance. Secretary of Justice legislature.
sent him a letter requiring him to explain why no - Considering the functions of the said Committee, i is
disciplinary action should be taken against petitioner for evident that it discharges administrative functions.
approving subdivision plans in excess of areas covered by Manzano’s membership in the said committee will be in
original titles. He was then suspended pending violation of the Constitution.
investigation for gross negligence and conduct prejudicial - Note that Court urged the judges to render assistance to
to public interest. Noblejas argued that as he enjoyed rank said Committees to help promote the laudable purposes
and privileges of a CFI judge, he can only be suspended in for which they exist, but only when such assistance may
same manner as the aforementioned position, and be reasonably incidental to the fulfillment of their judicial
therefore, his case can only be resolved by the SC. duties.

ISSUE/S:
DISSENT: observed, lest the principle of separation of powers on
• J. Gutierrez Jr: Administrative functions refer to which our government rests by mandate of the people
management actions, determinations, and orders of thru the Constitution be gradually eroded by practices
executive officials as they administer the laws and try to purportedly motivated by good intentions in the interest
make government effective. There is an element of of the public service.
positive action, of supervision or control. The membership - It is thus of grave importance to the judiciary under our
in the Provincial or City Committee on Justice would not present constitutional scheme of government that no
involve any regulation or control over the conduct and judge of even the lowest court in this Republic should
affairs of individuals. Neither will the Committee on place himself in a position where his actuations on
Justice promulgate rules and regulations nor exercise any matters submitted to him for action or resolution would
quasi-legislative functions. Its work is purely advisory. The be subject to review and prior approval and, worst still,
majority opinion suggests the giving of assistance by reversal, before they can have legal effect, by any
Judges to the work of the Committees on Justice. authority other than the Court of Appeals or this Supreme
Assistance is a vague term. If judges cannot become Courts, as the case may be.
members, why should they be allowed or even
encouraged to assist these Committees. The line drawn by
the majority is vague and unrealistic.
• J. Melencio-Herrera: The Committee on Justice cannot be
likened to such an administrative agency of government.
It is a study group with recommendatory functions. In fact,
membership by members of the Bench in said committee
is called for by reason of the primary functions of their
position.

GARCIA v. MACARAIG
FACTS: Garcia filed an administrative complaint against
Garcia in his former capacity as CFI judge for “dishonesty,
violation of oath of office, gross incompetence, and
violation of RA 296. Particularly, she alleges that Macaraig
didn’t submit monthly report of cases and hours in session
that the court held daily, and that he collected his salary
despite non submission of certificate of service in violation
of sec. 5, Judicial Act.

ISSUE/S:
1. WON Macaraig violated Sec. 5 of Judicial Act — NO
- Macaraig has not prepared and submitted any of the
reports of accomplishments and status of cases in his sala
because has not yet started performing any judicial
functions. However, he could not be blamed for not
actually holding office in the court to which he was
appointed was not of his making. The other officials in
charge of providing him therewith seem to have been
caught unprepared and have not had enough time to
have it ready.
- The line between what a judge may do and what he may
not do in collaborating or working with other offices or
officers under the other great departments of the
government must always be kept clear and jealously