Assignment No.

6
C. Quasi-Judicial Power (Adjudicatory)

determined authoritatively, finally and definitely, subject to such

appeals or modes of review as may be provided by law. This
function, to repeat, the Commission does not have.

Hence it is that the CHR having merely the power to

investigate, cannot and not try and resolve on the merits
(adjudicate) the matters involved in Striking Teachers HRC Case
No. 90-775, as it has announced it means to do; and cannot do so
even if there be a claim that in the administrative disciplinary
proceedings against the teachers in question, initiated and
Cases:
conducted by the DECS, their human rights, or civil or political
Carino v. Commission on Human Rights, 204 rights had been transgressed.
SCRA 483 (1991)
Megaworld
Globus
Asia,
Inc.
v.
DSM
Construction
and
Development
Corp.,
GR
No.
FACTS: On September 17, 1990, a Monday and a class day,
some 800 public school teacher, among them the 8 herein private 153310, March 2, 2004
respondents who were members of the Manila Public School
NAPOCOR v. Hon. Rose Marie Alonzo-Leasto,
Teachers Association (MPSTA) and Alliance of Concerned
GR No. 148318, Nov. 22,2004
Teachers (ACT) undertook mass concerted actions to
dramatize and highlight their plight resulting from the alleged
Lupangco v. Court of Appeals, 160 SCRA 848
failure of the public authorities to act upon grievances that had
(1988)
time and again been brought to the latters attention.
1. Definition
2. Distinguished from quasi-legislative
functions
3. Jurisdiction

The respondents were preventively suspended by the Secretary of

Education. They complained to CHR.

Lupo Lupangco vs CA G.R. No. 77372 April 29, 1988

160 SCRA 848
ISSUE: WON CHR has the power to adjudicate alleged human
Action
rights violations
: petition for certiorari to review the decision of the
Court of Appeals
RULING: No.
Issue
: Is the Regional Trial Court of the same category as
The Commission evidently intends to itself adjudicate, that is to
the Professional Regulation Commission so that
say, determine with the character of finality and definiteness, the
itcannot pass upon the validity of the administrative
same issues which have been passed upon and decided by the
acts of the latter.Commission lawfully prohibit the
Secretary of Education and subject to appeal to CSC, this Court
examines from attending review classes, receiving
having in fact, as aforementioned, declared that the teachers
handout materials, tips, orthe like three (3) days
affected may take appeals to the CSC on said matter, if still
before the date of the examination?
timely.
Facts:
Oct 6, 1986, (PRC) issued Resolution No. 105
The threshold question is whether or not the CHR has the power
"Additional Instructions to Examines," to all who will
under the constitution to do so; whether or not, like a court of
take thelicensure examinations in accountancy.
justice or even a quasi-judicial agency, it has jurisdiction or
No examinee shall attend any review class,
adjudicatory powers over, or the power to try and decide, or dear
briefing, conference or the like conducted by, or
and determine, certain specific type of cases, like alleged human
shall receive any
rights violations involving civil or political rights.
hand-out, review material, or any tip from any
school, college or university, or any review center or
The Court declares that the CHR to have no such power, and it
the like orany reviewer, lecturer, instructor official or
was not meant by the fundamental law to be another court or
employee of any of the aforementioned or similars
quasi-judicial agency in this country, or duplicate much less take
institutionsduring the three days immediatel
over the functions of the latter.
y proceeding every examination day including
examination day.
The most that may be conceded to the Commission in the way of
Any examinee violating this instruction shall be
adjudicative power is that it may investigate, i.e. receive evidence subject to the sanctions prescribed by Sec. 8, Art. III
and make findings of fact as regards claimed human rights
of the
violations involving civil and political rights. But fact-finding is
Rules and Regulations of the Commission.
not adjudication, and cannot be likened to judicial function of a
Oct 16, 196, petitioners et al, filed an injuction suit
court of justice, or even a quasi judicial agency or official. The
against PRC, in the RTC
function of receiving evidence and ascertaining therefrom the
RTC Held:
facts of a controversy is not a judicial function, properly
that it had jurisdiction to try the case and enjoined
speaking. To be considered such, the faculty of receiving evidence the
respondent
commission
from
enforcing
and making factual conclusions in a controversy must be
andgiving effect to Resolution No. 105 which it
accompanied by the authority of applying the law to those factual
found to be unconstitutional.PRC to CA
conclusions to the end that the controversy be decided or

Appeal
CA HELD
: RTC had no jurisdiction to entertain the case and to
enjoin the enforcement of the Resolution No.105,
stated as its basis its conclusion that the
Professional Regulation Commission and the
Regional Trial Courtare co-equal bodies.
That the petitioner Prof
essional Regulatory Commission is at least a coequal body with the Regional Trial Court is beyond
question, and co-equal bodies have no power to
control each other or interfere with each
other's acts. 3

representations to retain possession of the property

of Ancla, he thereby relinquishes whatever
responsibility he had over the said property since
Ancla surreptitiously withdrew his equipment from
him. In his reply, the BIR Reg. Dir. said that
Azarcons failure to comply with the provisions of
the warrant did not relieve him from his
responsibility.

Along with his co-accused, Azarcon was charged

before the Sandiganbayan with the crime of
malversation of public funds or property. On March
8, 1994, the Sandiganbayan rendered a Decision
sentencing the accused to suffer the penalty of
Lupangco to SC:
imprisonment ranging from 10 yrs and 1 day of
SC HELD: RTC has jurisdiction to entertain Civil Case prision mayor in its maximum period to 17 yrs, 4
No. 86-37950 and enjoin the respondent PRC mos and 1 day of reclusion temporal. Petitioner filed
fromenforcing its resolution.
a motion for new trial which was subsequently
RE: Reso 105:
denied by Sandiganbayan. Hence, this petition.
The unreasonableness is more obvious in that one
who is caught committing the prohibited acts even Issue: Whether or not Sandiganbayan has
withoutany ill motives will be barred from taking jurisdiction over a private individual designated by
future examinations conducted by the respondent BIR as a custodian of distrained property.
PRC. Furthermore,it is inconceivable how the
Commission can manage to have a watchful eye on Held: SC held that the Sandiganbayans decision
each and every examineeduring the three days was null and void for lack of jurisdiction.
before the examination period.It is an aixiom in
administrative law that administrative authorities Sec. 4 of PD 1606 provides for the jurisdiction of the
should not act arbitrarily and capriciously inthe Sandiganbayan. It was specified therein that the
issuance of rules and regulations. To be valid, such only instances when the Sandiganbayan will have
rules and regulations must be reasonable and jurisdiction over a private individual is when the
fairlyadapted to the end in view. If shown to bear no complaint charges the private individual either as a
reasonable relation to the purposes for which they co-principal, accomplice or accessory of a public
areauthorized to be issued, then they must be held officer or employee who has been charged with a
to be invalid. 22
crime within its jurisdiction.
Chin v. Land Bank of the Philippines, 201 SCRA The Information does no charge petitioner Azarcon
190 (1991)
of becoming a co-principal, accomplice or accessory
to a public officer committing an offense under the
Azarcon v. Sandiganbayan, 268 SCRA 747 Sandiganbayans jurisdiction. Thus, unless the
(1997)
petitioner be proven a public officer, Sandiganbayan
will have no jurisdiction over the crime charged.
Facts: Petitioner Alfredo Azarcon owned and
operated an earth-moving business, hauling dirt and Art. 203 of the RPC determines who public officers
ore. His services were contracted by PICOP. are. Granting that the petitioner, in signing the
Occasionally, he engaged the services of sub- receipt for the truck constructively distrained by the
contractors like Jaime Ancla whose trucks were left BIR, commenced to take part in an activity
at the formers premises.
constituting public functions, he obviously may not
be deemed authorized by popular election. Neither
On May 25, 1983, a Warrant of Distraint of Personal was he appointed by direct provision of law nor by
Property was issued by BIR commanding one of its competent authority. While BIR had authority to
Regional Directors to distraint the goods, chattels or require Azarcon to sign a receipt for the distrained
effects and other personal property of Jaime Ancla, a truck, the National Internal Revenue Code did not
sub-contractor of accused Azarcon and a delinquent grant it power to appoint Azarcon a public officer.
taxpayer. A Warrant of Garnishment was issued to The BIRs power authorizing a private individual to
and subsequently signed by accused Azarcon act as a depositary cannot be stretched to include
ordering him to transfer, surrender, transmit and/or the power to appoint him as a public officer. Thus,
remit to BIR the property in his possession owned by Azarcon is not a public officer.
Ancla. Azarcon then volunteered himself to act as
custodian of the truck owned by Ancla.
After some time, Azarcon wrote a letter to the Reg.
Dir of BIR stating that while he had made