Primary Holding
The Supreme Court declared Section 32 of Republic Act No. 9173 valid, and voided and declared unconstitutional the provisions of Joint Resolution No. 4 and Executive Order No. 811 that purported to amend or repeal Section 32. However, the Court refused to compel the government to implement Section 32 due to the absence of an appropriation law.
Background
The case arose after the issuance of Executive Order No. 811, which downgraded the entry-level salary of government nurses to Salary Grade 11, contrary to Section 32 of Republic Act No. 9173. Ang Nars Party-List and PSLINK filed the petition, asserting that the downgrade was unconstitutional and beyond the authority of the Executive.
History
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October 13, 2014: Petitioners requested legal opinions from DOJ, DBM, and DOH.
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2014: Unsatisfactory replies led to the filing of the petition before the Supreme Court.
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The case included oral arguments, submission of position papers, and motions to intervene.
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May 28, 2019: Philippine Nurses Association filed a petition-in-intervention, which was dismissed for being filed late.
Facts
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1.
EO No. 811 downgraded government nurses' salary to Salary Grade 11.
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2.
RA No. 9173 mandated Salary Grade 15 for government nurses.
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3.
Petitioners argued that EO No. 811 and Joint Resolution No. 4 violated the law.
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4.
Government argued EO No. 811 was valid under Joint Resolution No. 4.
Arguments of the Petitioners
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1.
Joint Resolution No. 4 did not authorize the President to revise salary grades.
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2.
EO No. 811 violated RA No. 9173 and the principle of non-diminution of benefits.
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3.
EO No. 811 cannot amend or repeal an existing law.
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4.
Grave abuse of discretion by respondents in downgrading the salary grade.
Arguments of the Respondents
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1.
Petitioners lacked legal standing.
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2.
Incorrect remedy was sought (should have been declaratory relief).
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3.
Joint Resolution No. 4, having the force of law, amended RA No. 9173.
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4.
Implementation of RA No. 9173 would create salary distortions.
Issues
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1.
Whether respondents committed grave abuse of discretion in downgrading the salary grade.
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2.
Whether Joint Resolution No. 4 amended Section 32 of RA No. 9173.
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3.
Whether the Court can compel the implementation of Section 32 of RA No. 9173.
Ruling
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1.
Declared Section 32 of RA No. 9173 valid.
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2.
Declared provisions of Joint Resolution No. 4 and EO No. 811 void and unconstitutional.
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3.
Refused to compel implementation of Section 32 due to lack of appropriation law.
Rationale
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1.
Only bills can become laws under Constitution
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2.
Joint resolutions cannot amend or repeal laws
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3.
Executive orders cannot modify statutory provisions
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4.
Power of the purse belongs exclusively to Congress
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5.
Implementation requires specific appropriation law
Doctrines
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1.
Principle of Non-Diminution of Benefits
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2.
Doctrine of Separation of Powers
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3.
Hierarchy of Courts and Exceptions Due to Transcendental Importance
Key Excerpts
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1.
"A mere joint resolution cannot amend a law."
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2.
"The power of the purse belongs exclusively to Congress."
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3.
"No money shall be paid out of the Treasury except in pursuance of an appropriation made by law."
Precedents Cited
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1.
Bayan Muna v. Romulo: Legal standing of party-list representatives.
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2.
David v. Macapagal-Arroyo: Doctrine of transcendental importance.
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3.
INS v. Chadha: On the legislative process and constitutionality of joint resolutions.
Statutory and Constitutional Provisions
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1.
Section 32 of RA No. 9173 (Philippine Nursing Act of 2002)
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2.
Article VI, Section 24: Legislative power over appropriations
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3.
Article VI, Section 25: Requirements for appropriation bills
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4.
Article VI, Section 26: Three-reading requirement
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5.
Article VI, Section 29: Treasury disbursements