GR L 57883; (March, 1982) (Digest)
G.R. No. L-57883, March 12, 1982
GUALBERTO J. DE LA LLANA, et al., petitioners, vs. MANUEL ALBA, et al., respondents.
FACTS
Petitioners, led by a presiding judge and joined by several members of the bar, assailed the constitutionality of Batas Pambansa Blg. 129, the Judiciary Reorganization Act of 1980. The law mandated the reorganization of the judiciary, stipulating that incumbent justices and judges of inferior courts (except those of the Sandiganbayan and Court of Tax Appeals) would be considered separated from their positions unless appointed to the new courts established by the Act. Petitioners filed a suit, treated as an action for prohibition, seeking to enjoin the respondents—the Minister of Budget, the Chairman of the Commission on Audit, and the Minister of Justice—from implementing the law. They contended that the statute violated the constitutional security of tenure of judicial officers, undermined judicial independence, was enacted in bad faith, and constituted an undue delegation of legislative power to the President concerning compensation and the reorganization’s completion date.
ISSUE
The core issue is whether Batas Pambansa Blg. 129 is unconstitutional for allegedly violating the security of tenure of members of the judiciary and the principle of judicial independence.
RULING
The Supreme Court, sitting en banc, upheld the constitutionality of Batas Pambansa Blg. 129. The Court resolved the threshold question of legal standing in favor of petitioners. Presiding Judge de la Llana possessed a direct and substantial interest as his incumbency was affected, satisfying the requirement for challenging a statute. The other petitioners, as members of the bar and officers of the court, were also deemed to have a sufficient interest in the integrity of the judicial system.
On the substantive challenge, the Court ruled that the Batasang Pambansa possessed the plenary legislative power to reorganize the judiciary, which includes the authority to abolish courts and consequently the offices of the judges presiding over them, provided the abolition is done in good faith. The Court found that the reorganization was a bona fide exercise of this power, aimed at improving the efficiency and administration of justice, and was not a mere pretext to remove incumbent judges. The security of tenure guaranteed by the Constitution is not a guarantee of perpetual tenure in a specific position but secures tenure only during good behavior until retirement age, provided the office itself exists. The abolition of the office, when done in good faith as part of a genuine reorganization, results in no removal but a permissible cessation of the office. The Court also found no merit in the allegations of undue delegation or bad faith, noting the extensive studies and deliberations that preceded the law’s enactment. The separation of the incumbents was a necessary consequence of a valid legislative reorganization, not an unconstitutional removal.