Quintos-Deles vs. Commission on Constitutional Commissions

The Court held that appointments of sectoral representatives to the House of Representatives made by the President pursuant to Article XVIII, Section 7 of the 1987 Constitution are subject to confirmation by the Commission on Appointments. Such appointments are encompassed by the first sentence of Article VII, Section 16, which requires consent for "other officers whose appointments are vested in him in this Constitution."

Pursuant to the transitory provisions of the 1987 Constitution, the President appointed Teresita Quintos-Deles and three others as sectoral representatives to the House of Representatives on April 6, 1988. Their scheduled oath-taking was suspended after members of the Commission on Appointments insisted that confirmation was required prior to assumption of office. The President subsequently submitted the appointments for confirmation by the Commission on Appointments. The petitioner then filed a special civil action for prohibition and mandamus, arguing that her appointment did not require confirmation.

On April 6, 1988, President Corazon C. Aquino appointed Teresita Quintos-Deles as sectoral representative for women, along with three others for youth, peasant, and urban poor sectors, pursuant to Article VII, Section 16, paragraph 2 and Article XVIII, Section 7 of the Constitution. The appointments were transmitted to the Speaker of the House. On April 18, 1988, the oath-taking of the appointees was suspended due to opposition from members of the Commission on Appointments, who insisted on prior confirmation. On April 25, 1988, the President submitted the appointments for confirmation by the Commission on Appointments. The petitioner questioned the Commission's jurisdiction, but the Committee on Constitutional Commissions and Offices ruled against her position. The petitioner's appointment was not acted upon before Congress adjourned.

Petitioner maintained that her appointment as a sectoral representative under Article XVIII, Section 7 of the Constitution does not require confirmation by the Commission on Appointments. She argued that no constitutional provision or Executive Order No. 198 mandates such confirmation. She contended that subjecting her appointment to confirmation, while previous sectoral representatives were not, would be discriminatory.

Respondents, adopting the Solicitor General's position, argued that because the President submitted the petitioner's appointment for confirmation by the Commission on Appointments, confirmation was required. They contended that sectoral representatives are "other officers whose appointments are vested in him in this Constitution" under Article VII, Section 16, and thus fall within the class of presidential appointees requiring consent. They further argued that the petitioner's appointment, made during a congressional recess, explicitly invoked the recess-appointment clause which inherently subjects the appointment to Commission action.

• Procedural Issues: Whether the case had become moot and academic because Congress adjourned without the Commission on Appointments acting on the appointment.
• Substantive Issues: Whether the appointment of a sectoral representative to the House of Representatives under Article XVIII, Section 7 of the 1987 Constitution requires confirmation by the Commission on Appointments.

• Procedural: The Court did not dismiss the case on mootness. It proceeded to resolve the substantive constitutional issue despite the appointment's lapse, recognizing the question's recurrence and public importance.
• Substantive: The Court ruled that confirmation by the Commission on Appointments is required. It applied the doctrine from Sarmiento v. Mison, which held that only appointments enumerated in the first sentence of Article VII, Section 16 require consent. The Court found that sectoral representatives, whose appointment authority is vested in the President by the Constitution (Article XVIII, Section 7), fall under the catch-all phrase "other officers whose appointments are vested in him in this Constitution." The Court emphasized that the President's own act of submitting the appointment for confirmation and the appointment's explicit reference to the recess-appointment clause (Article VII, Section 16(2)) further confirmed this interpretation.

• Sarmiento v. Mison Doctrine — This doctrine interprets Article VII, Section 16 of the 1987 Constitution to mean that only appointments to positions explicitly mentioned in the first sentence of said section require confirmation by the Commission on Appointments. The Court applied this doctrine to classify sectoral representatives as "other officers whose appointments are vested in him in this Constitution," thereby requiring confirmation.

• "Since the seats reserved for sectoral representatives in paragraph 2, Section 5, Art. VI may be filled by appointment by the President by express provision of Section 7, Art. XVIII of the Constitution, it is undubitable that sectoral representatives to the House of Representatives are among the 'other officers whose appointments are vested in the President in this Constitution,' referred to in the first sentence of Section 16, Art. VII whose appointments are subject to confirmation by the Commission on Appointments."
• "If indeed appointments of sectoral representatives need no confirmation, the President need not make any reference to the constitutional provisions above-quoted in appointing the petitioner."

• Sarmiento v. Mison, et al., 156 SCRA 549 (1987) — This case established the controlling interpretation of Article VII, Section 16, limiting the Commission on Appointments' confirmation power to the officers enumerated in the first sentence. The Court relied on this precedent to categorize the petitioner's appointment.
• Mary Concepcion Bautista v. Sen. Jovito Salonga, et al., G.R. No. 86439, April 13, 1989 — This case reiterated the Mison doctrine. The Court cited it to demonstrate the consistent application of the principle that only specific presidential appointments require confirmation.

• Article VI, Section 5(1) and (2) of the 1987 Constitution — Provides for the composition of the House of Representatives, including the allocation of seats for party-list and sectoral representatives.
• Article VII, Section 16 of the 1987 Constitution — Enumerates the officers the President shall appoint, specifying which appointments require the consent of the Commission on Appointments. The first sentence was central to the Court's ruling.
• Article XVIII, Section 7 of the 1987 Constitution — A transitory provision authorizing the President to appoint sectoral representatives until a law is passed providing for their election. This was the direct source of the President's appointment power in this case.