Executive Order No. 284 is unconstitutional because it allows members of the Cabinet, their undersecretaries, and assistant secretaries to hold multiple offices or employment in contravention of the express prohibition in Section 13, Article VII of the 1987 Constitution, which provides a stricter rule for these officials compared to the general rule for other appointive officials in Section 7, Article IX-B. The only exceptions to this prohibition are those expressly provided in the Constitution itself, or positions held in an ex-officio capacity without additional compensation and as required by the primary functions of their office.

The case arose from the issuance of Executive Order No. 284 by President Corazon C. Aquino on July 25, 1987. This E.O. allowed members of the Cabinet, undersecretaries, assistant secretaries, and other appointive officials of the Executive Department to hold, in addition to their primary positions, not more than two positions in the government and government corporations and receive corresponding compensation. This was issued following DOJ Opinion No. 73, s. 1987, which interpreted Section 13, Article VII in relation to Section 7, par. (2), Article IX-B of the Constitution. The practice of high-ranking executive officials holding multiple government posts, often with substantial emoluments, had been a contentious issue, particularly during the Marcos regime, and the 1987 Constitution sought to address this.

• President Corazon C. Aquino issued Executive Order No. 284 on July 25, 1987.
• Section 1 of E.O. No. 284 allowed a member of the Cabinet, undersecretary, assistant secretary, or other appointive officials of the Executive Department to hold not more than two additional positions in the government and government corporations and receive compensation therefor, even if allowed by law or by the ordinary functions of his position, with an exception for ad hoc bodies or committees where the President is Chairman.
• Section 3 of E.O. No. 284 mandated that at least one-third (1/3) of the members of the boards of government-owned or controlled corporations should be a secretary, or undersecretary, or assistant secretary.
• Petitioners, Civil Liberties Union and Anti-Graft League of the Philippines, Inc., challenged the constitutionality of E.O. No. 284, alleging it violated Section 13, Article VII of the 1987 Constitution.
• Section 13, Article VII of the Constitution prohibits the President, Vice-President, Members of the Cabinet, and their deputies or assistants from holding any other office or employment during their tenure, unless otherwise provided in the Constitution.
• The Anti-Graft League of the Philippines also sought writs of prohibition and mandamus against public respondents holding multiple positions and to compel them to return benefits received.
• The issuance of E.O. No. 284 was based on DOJ Opinion No. 73, s. 1987, which opined that Cabinet members, their deputies, and assistant secretaries could hold other public office if allowed by law or by the primary functions of their positions, referencing Section 7, par. (2), Article IX-B of the Constitution.

• Executive Order No. 284 runs counter to Section 13, Article VII of the 1987 Constitution, which imposes an absolute prohibition on the President, Vice-President, Cabinet members, and their deputies or assistants from holding any other office or employment during their tenure, unless otherwise provided in this Constitution.
• The phrase "unless otherwise provided in this Constitution" limits exceptions to those expressly stated in the Constitution itself, such as the Vice-President being appointed as a Cabinet member (Article VII, Section 3, par. 2) or the Secretary of Justice being an ex-officio member of the Judicial and Bar Council (Article VIII, Section 8(1)).
• Section 7, par. (2), Article IX-B of the Constitution, which allows appointive officials to hold other offices if "allowed by law or by the primary functions of his position," applies to appointive officials in general, not to the specific high-ranking officials covered by the stricter prohibition in Section 13, Article VII.
• DOJ Opinion No. 73 and E.O. No. 284 erroneously "lumped together" and created a "strained linkage" between the distinct provisions of Section 13, Article VII and Section 7, par. (2), Article IX-B, thereby diluting the stricter prohibition intended for the President and his official family.

• Executive Order No. 284 is constitutional as it was promulgated pursuant to DOJ Opinion No. 73, s. 1987, which correctly interpreted Section 13, Article VII in relation to Section 7, par. (2), Article IX-B of the Constitution.
• The phrase "unless otherwise provided in this Constitution" in Section 13, Article VII makes reference to the exceptions provided in Section 7, par. (2), Article IX-B, which allows appointive officials (including Cabinet members, their deputies, and assistants) to hold other office or employment if allowed by law or by the primary functions of their position.
• DOJ Opinions No. 129, s. 1987, and No. 155, s. 1988, clarified that the limitation in E.O. No. 284 does not apply to ex-officio positions or positions allowed by the primary functions of the public official, but only to disparate positions.
• A strict application of the prohibition would lead to impractical consequences, stripping Cabinet members of their ex-officio roles essential for government operations.

• Whether Executive Order No. 284 is unconstitutional for violating Section 13, Article VII of the 1987 Constitution.
• Whether the prohibition in Section 13, Article VII of the 1987 Constitution, concerning Cabinet members, their deputies or assistants holding other offices, admits of the exceptions provided for appointive officials in general under Section 7, par. (2), Article IX-B of the Constitution.
• Whether positions held by Cabinet members, their deputies or assistants in an ex-officio capacity without additional compensation and as required by their primary functions fall under the prohibition of Section 13, Article VII.

• Yes, Executive Order No. 284 is unconstitutional. It contravenes Section 13, Article VII of the 1987 Constitution by allowing Cabinet members, undersecretaries, or assistant secretaries to hold multiple offices or employment beyond what is permitted by the Constitution.
• No, the prohibition in Section 13, Article VII does not admit of the broad exceptions in Section 7, par. (2), Article IX-B. The framers intended a stricter prohibition for the President, Vice-President, Cabinet members, and their deputies/assistants. The phrase "unless otherwise provided in this Constitution" in Section 13, Article VII refers only to exceptions expressly stated in the Constitution itself.
• No, positions occupied by Executive officials in an ex-officio capacity as provided by law and as required by the primary functions of their office, without receiving additional compensation, do not constitute "any other office" within the contemplation of Section 13, Article VII. These are considered an imposition of additional duties, not separate offices.
• The Court ordered the named respondent public officials still holding such additional offices to immediately relinquish them. However, emoluments received by respondents for actual services rendered in the questioned positions may be retained, as they were considered de facto officers acting in good faith.

• Constitutional Construction (Intent of the Framers) — A Constitution should be construed to accomplish the objects of its adoption and to remedy the evils sought to be prevented. The Court examined the historical context of the 1987 Constitution, noting the public discontent with the Marcos-era practice of officials holding multiple positions, to discern the intent behind Section 13, Article VII as imposing a stricter prohibition.
• Constitutional Construction (Harmonization of Provisions) — Provisions of the Constitution bearing upon a particular subject should be considered and interpreted together to effectuate the whole purpose of the instrument. One section should not defeat another if they can reasonably stand together. The Court harmonized Section 13, Article VII and Section 7, Article IX-B by interpreting the former as a specific, stricter rule for high executive officials, and the latter as a general rule for other appointive officials.
• Constitutional Construction (Literal Interpretation of Prohibitory Language) — Where the language used in the constitution is prohibitory, it is to be understood as intended to be a positive and unequivocal negation. The Court applied this to the phrase "unless otherwise provided in this Constitution" in Section 13, Article VII, limiting exceptions to those explicitly found within the Constitution.
• Ex-Officio Capacity — Refers to an authority derived from official character merely, not expressly conferred upon the individual, but rather annexed to the official position. An ex-officio member of a board is one who is a member by virtue of his title to a certain office, without further warrant or appointment. The Court ruled that posts occupied by Executive officials in an ex-officio capacity as provided by law and required by their primary functions, without additional compensation, do not constitute "any other office" under Section 13, Article VII, as these are additional duties to the primary office.
• Primary Functions of Office — Refers to the chief or principal functions of an official. Additional duties must not only be closely related to but must be required by the official's primary functions to be permissible exceptions to the rule against holding multiple offices for Cabinet members, et al., under the ex-officio doctrine.
• De Facto Officer Doctrine — One who, in good faith, has had possession of an office and has discharged the duties pertaining thereto under color of authority, but without de jure title, is a de facto officer. Such an officer is legally entitled to the emoluments of the office for actual services rendered, especially where there is no de jure officer. The Court applied this doctrine to allow respondents to retain emoluments received from the additional positions held under the unconstitutional E.O. No. 284, as they acted in good faith.

• "The prohibition imposed on the President and his official family is therefore all-embracing and covers both public and private office or employment."
• "Thus, while all other appointive officials in the civil service are allowed to hold other office or employment in the government during their tenure when such is allowed by law or by the primary functions of their positions, members of the Cabinet, their deputies and assistants may do so only when expressly authorized by the Constitution itself."
• "The prohibition against holding dual or multiple offices or employment under Section 13, Article VII of the Constitution must not, however, be construed as applying to posts occupied by the Executive officials specified therein without additional compensation in an ex-officio capacity as provided by law and as required by the primary functions of said officials' office."
• "The ex oficio position being actually and in legal contemplation part of the principal office, it follows that the official concerned has no right to receive additional compensation for his services in the said position. The reason is that these services are already paid for and covered by the compensation attached to his principal office."
• "Ostensibly restricting the number of positions that Cabinet members, undersecretaries or assistant secretaries may hold in addition to their primary position to not more than two (2) positions in the government and government corporations, Executive Order No. 284 actually allows them to hold multiple offices or employment in direct contravention of the express mandate of Section 13, Article VII of the 1987 Constitution prohibiting them from doing so, unless otherwise provided in the 1987 Constitution itself."

• Maxwell vs. Dow — Cited for the principle of constitutional construction that the Court should bear in mind the object sought to be accomplished by a Constitution's adoption and the evils sought to be prevented or remedied.
• Rafael vs. Embroidery and Apparel Control and Inspection Board — Cited to explain the meaning of an ex-officio position, emphasizing that individuals designated to such positions merely perform duties in addition to those already performed under their original appointments, without needing new appointments.
• Castillo vs. Arrieta — Cited in support of the de facto officer doctrine, allowing respondents who acted in good faith under the subsequently invalidated E.O. No. 284 to retain emoluments for services rendered.
• Patterson vs. Benson — Cited for the equitable grounds supporting the de facto officer doctrine, stating it is unjust for the public to benefit from services of a de facto officer and then be freed from liability to pay for such services.

• 1987 Constitution, Article VII, Section 13 — This is the central provision prohibiting the President, Vice-President, Cabinet Members, and their deputies or assistants from holding any other office or employment during their tenure, unless otherwise provided in the Constitution. It was the basis for declaring E.O. 284 unconstitutional.
• 1987 Constitution, Article IX-B, Section 7, par. (2) — This provision states that "Unless otherwise allowed by law or by the primary functions of his position, no appointive official shall hold any other office or employment in the government..." Respondents argued this provided an exception applicable to Cabinet members, but the Court ruled it is a general rule for other appointive officials, distinct from the stricter rule in Art. VII, Sec. 13.
• 1987 Constitution, Article VII, Section 3, par. (2) — Cited as an example of an exception "otherwise provided in this Constitution" where the Vice-President may be appointed as a Member of the Cabinet.
• 1987 Constitution, Article VIII, Section 8 (1) — Cited as an example of an exception "otherwise provided in this Constitution" where the Secretary of Justice is an ex-officio member of the Judicial and Bar Council.
• 1987 Constitution, Article VI, Section 13 — Referenced for comparison, showing a similar prohibition against Senators or Members of the House of Representatives holding other government offices.
• 1987 Constitution, Article XVI, Section 5(4) — Referenced for comparison, showing a prohibition against active members of the armed forces being appointed to civilian positions.
• 1987 Constitution, Article VII, Section 17 — Referenced in relation to the President's power of control over executive departments, bureaus, and offices, which justifies mandating additional duties in an ex-officio capacity for efficiency and coordination.
• Executive Order No. 284 — The assailed executive order, which allowed Cabinet members, their deputies, and assistants to hold up to two additional government positions. Declared unconstitutional by the Court.