Crisostomo Vs Court of Appeals, 258 SCRA 134 Case Digest (Administrative Law)
Crisostomo Vs Court of Appeals, 258 SCRA 134 Case Digest (Administrative Law)
ISSUE: Whether or not the conversion of the PCC into PUP abolished the PCC
RULING: No. In part the contention is well taken, but, as will presently be explained, reinstatement is no
longer possible because of the promulgation of P.D. No. 1437 by the President of the Philippines on June
10, 1978.
P.D. No. 1341 did not abolish, but only changed, the former Philippine College of Commerce into what is
now the Polytechnic University of the Philippines, in the same way that earlier in 1952, R.A. No. 778 had
converted what was then the Philippine School of Commerce into the Philippine College of Commerce.
What took place was a change in academic status of the educational institution, not in its corporate life.
Hence the change in its name, the expansion of its curricular offerings, and the changes in its structure
and organization.
As petitioner correctly points out, when the purpose is to abolish a department or an office or an
organization and to replace it with another one, the lawmaking authority says so.
But the reinstatement of petitioner to the position of president of the PUP could not be ordered by the trial
court because on June 10, 1978, P.D. No. 1437 had been promulgated fixing the term of office of presidents
of state universities and colleges at six (6) years, renewable for another term of six (6) years, and
authorizing the President of the Philippines to terminate the terms of incumbents who were not
reappointed.
RATIO: When the purpose is to abolish a department or an office or an organization and to replace it with
another one, the lawmaking authority says so. What took place was a change in academic status of the
educational institution, not in its corporate life. Hence the change in its name, the expansion of its
curricular offerings, and the changes in its structure and organization.
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