G.R. No. L-19553. February 29, 1964.
JOSE V. RODRIGUEZ, ET AL., petitioners-appellants, vs. IGNACIO SANTOS DIAZ, ET AL., respondents-appellees.

FACTS

President Diosdado Macapagal issued Administrative Order No. 4 on January 30, 1962, ordering an immediate investigation of the National Rice and Corn Corporation (NARIC) to determine the causes of its failure to achieve its statutory objectives. Pending investigation, petitioners Jose V. Rodriguez (Chairman of the Board), Maximo Calalang, Conrado Estrella, and Ramon Enriquez (Board Members) were suspended. Ignacio Santos Diaz was appointed as the presidential investigator. Subsequently, additional administrative charges were filed against Rodriguez in his capacity as NARIC Acting General Manager, which were ordered to be investigated jointly with the initial matters.
During the hearing, petitioners questioned the jurisdiction of the presidential investigator over Rodriguez as Acting General Manager, arguing that under Republic Act No. 663 , the power to appoint and discipline the general manager resided solely in the NARIC Board of Directors, not the President. The investigator overruled the objection. Petitioners then filed a petition for prohibition with preliminary injunction before the Court of First Instance of Manila, seeking to restrain the investigation of Rodriguez in his managerial capacity for alleged lack of jurisdiction. The lower court ultimately dismissed the petition.

ISSUE

Whether the President, through a designated investigator, had jurisdiction to conduct an administrative investigation into the acts of Jose V. Rodriguez in his capacity as Acting General Manager of the NARIC.

RULING

The Supreme Court affirmed the dismissal of the petition, ruling that the issue had become academic and that the President’s investigative authority was proper. The investigation petitioners sought to prohibit had already concluded by the time the appeal was heard. More fundamentally, Rodriguez had already been effectively relieved of his position as Acting General Manager upon the appointment of Jose Y. Feliciano as General Manager on January 26, 1962. As held in prior jurisprudence, an acting appointment is precarious, and the holder may be relieved at any time without cause or hearing.
Consequently, the investigation of Rodriguez’s managerial acts could no longer be for the purpose of his removal, as he was already relieved. The Court clarified that the purpose of the investigation was fact-finding—to aid the President in determining why the NARIC failed its objectives, particularly in price stabilization. Such an inquiry is not punitive but informational, falling within the President’s executive power to enforce laws and ensure the proper implementation of government programs. Therefore, the President could validly order an investigation into Rodriguez’s conduct as Acting General Manager, notwithstanding the NARIC Board’s statutory power to appoint and discipline the manager, as the inquiry was a separate executive function aimed at gathering information for governance. The petition for prohibition was without merit.