G.R. No. 149724 ; August 19, 2003
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES, represented herein by its Secretary, HEHERSON T. ALVAREZ, Petitioner, vs. DENR REGION 12 EMPLOYEES, represented by BAGUIDALI KARIM, Acting President of COURAGE (DENR Region 12 Chapter), Respondents.

FACTS

The Regional Executive Director of DENR Region XII issued a Memorandum directing the immediate transfer of the regional offices from Cotabato City to Koronadal, South Cotabato. This directive was issued pursuant to DENR Administrative Order (DAO) No. 99-14, which authorized the realignment of administrative units. The DAO itself was issued as an interim administrative arrangement to improve efficiency, pending congressional approval of a government-wide reorganization, and was anchored on Executive Order No. 192. The respondent DENR employees, through their association, filed a petition for nullity with the Regional Trial Court (RTC) of Cotabato, which granted a temporary restraining order and later a permanent injunction, ordering the return of the offices to Cotabato City. The RTC ruled the transfer was bereft of legal basis and issued with grave abuse of discretion.

ISSUE

The primary issues were: (1) the validity of DAO 99-14 and the implementing Memorandum; and (2) whether the DENR Secretary has the authority to reorganize the DENR, including relocating regional offices.

RULING

The Supreme Court GRANTED the petition, reversing the lower courts. On procedure, the Court relaxed the rules, as the dismissal by the Court of Appeals on technical grounds would defeat substantial justice concerning a significant public interest. On the merits, the Court upheld the DENR’s authority. The power to reorganize the DENR is executive in nature, derived from E.O. No. 192 (the DENR’s charter), which grants the Secretary control and supervision over the department. DAO 99-14 was a valid exercise of this administrative authority aimed at improving service delivery. The transfer of regional offices, as part of this administrative realignment, is an executive function concerning governmental efficiency. The Court emphasized the doctrine of separation of powers, stating that the judiciary cannot inquire into the wisdom or expediency of such executive acts absent a clear showing of constitutional infirmity or grave abuse of discretion. No such abuse was demonstrated, as the act was performed under a presumed regularity of official functions and within the Secretary’s delegated powers. The employees had no vested right to insist on the office remaining at a specific location.