Professional Documents
Culture Documents
In Re Designation of Judge Manzano As Member of Ilocos Norte Provincial Committe On Justice (Case Digest)
In Re Designation of Judge Manzano As Member of Ilocos Norte Provincial Committe On Justice (Case Digest)
MANZANO AS MEMBER OF
THE ILOCOS NORTE PROVINCIAL COMMITTEE ON JUSTICE. [A.M. No. 88-7-
1861-RTC. October 5, 1988.]
FACtS
On July 4 1988, Judge Rodolfo U. Manzano Executive Judge, RTC, Bangui, Ilocos Norte, Branch
19, submitted a letter to the Supreme Court indicating that by virtue of EO No. RF6-04 issued on
June 21, 1988, he was appointed by then Ilocos Norte Gov. Rodolfo C. Fariñas, as a member of
the Ilocos Norte Provincial Committee on Justice. The letter indicates that before Judge Manzano
accepts the appointment and enter in the discharge of powers and duties as a member of the said
committee, he deemed it fit to seek for the following:
(1) SC’s authorization for Judge Manzano to accept the appointment and assume and
discharge the powers and duties of the said position
(2) SC’s consideration that such membership is neither violative of the Independence of the
Judiciary nor a violation of Section 12, Article VIII, or of the second paragraph of Section 7, Article
IX (B), both of the Constitution, and will not in any way amount to an abandonment of my present
position as Executive Judge of Branch XIX, Regional Trial Court, First Judicial Region, and as a
member of the Judiciary; and
(3) SC’s consideration that such membership is part of the primary functions of an
Executive Judge
ISSU
E
WON the membership of Judge Manzano in Ilocos Norte Provincial Committee on Justice is
constitutional
RULING
The Supreme Court ruled that Judge Manzano’s membership in the Ilocos Norte Provincial
Committee on Justice is UNCONSTITUTIONAL
An examination of Executive Order No. 856, as amended, reveals that Provincial/City Committees
on Justice are created to ensure the speedy disposition of cases of detainees, particularly those
involving the poor and indigent ones, thus alleviating jail congestion and improving local jail
conditions. It is evident that such Provincial/City Committees on Justice perform administrative
functions. Administrative functions are those which involve the regulation and control over the
conduct and affairs of individuals for their own welfare and the promulgation of rules and
regulations to better carry out the policy of the legislature or such as are devolved upon the
administrative agency by the organic law of its existence.
Under Section 12, Art. VIII, Constitution, members of the Supreme Court and other courts
established by law shall not be designated to any agency performing quasi-judicial or
administrative functions. Considering that membership of Judge Manzano in the Ilocos Norte
Provincial Committee on Justice, which discharges administrative functions, will be in violation of
the Constitution, the SC is constrained to deny his request. Even as non-members of
Provincial/City Committees on Justice, RTC judges should render assistance to said Committees
to help promote the laudable purposes for which they exist, but only when such assistance may
be reasonably incidental to the fulfillment of their judicial duties