G.R. No. 109638 and G.R. No. 109639 March 31, 1995
PNP SUPT. FLORENCIO D. FIANZA, petitioner, vs. THE PLEB (PEOPLE’S LAW ENFORCEMENT BOARD) of the CITY OF BAGUIO; the NATIONAL POLICE COMMISSION (NAPOLCOM), SPO3 FERNANDO TAFALENG, PO3 OCTAVIO PAWINGI, PO2 FERDINAND SEGUNDO, PO3 METODIO AQUINO, PO3 BENJAMIN NAKIGO, PO3 SALVADOR GALISTE, PO3 ROMEO BAUTISTA and PO3 ALFREDO MATIAS, respondents.

PNP SUPT. JULY CORDOVIZ, petitioner, vs. The PLEB (PEOPLE’S LAW ENFORCEMENT BOARD) of the CITY OF BAGUIO, the NATIONAL POLICE COMMISSION (NAPOLCOM) and PAT. RAY EKID respondents.

FACTS

These are consolidated petitions for prohibition and declaratory relief. In G.R. No. 109638 , respondent policemen (SPO3 Fernando Tafaleng, et al.) filed an amended complaint with the Baguio PLEB against petitioner PNP Supt. Florencio D. Fianza and another officer for “Grave Misconduct and Irregularity in the Performance of Duty.” The complaint alleged that petitioner Fianza issued illegal and irregular orders for their transfer from the Baguio City Police Station to other stations and for their being dropped from the rolls, which actions were allegedly in retaliation for raids they conducted on jueteng operations. Petitioner Fianza contended that the PLEB had no jurisdiction as it was not a “citizen’s complaint” but an internal organizational matter of the PNP involving transfer and deployment orders. The PLEB ruled it had jurisdiction, a view upheld by the NAPOLCOM Acting Regional Director, who opined that “citizen’s complaint” includes complaints filed by any citizen, whether a government employee or an ordinary person.
In G.R. No. 109639, petitioner PNP Supt. July Cordoviz similarly contested the PLEB’s jurisdiction over an administrative case filed against him by Pat. Ray Ekid for alleged threats. The PLEB also denied Cordoviz’s motion to dismiss.
Petitioners argued that the PLEB’s jurisdiction is limited to citizen’s complaints initiated by private citizens qua private citizens, not by PNP members in their official capacity. They asserted that complaints involving internal discipline, such as transfers and reassignments under the command authority of PNP officials, should be raised with their superiors.

ISSUE

Whether the People’s Law Enforcement Board (PLEB) has jurisdiction over administrative complaints filed by PNP personnel against their superior officers.

RULING

No. The Supreme Court ruled that the PLEB does not have jurisdiction over administrative complaints filed by PNP members against their superiors. The Court held that the PLEB’s jurisdiction, as provided under Republic Act No. 6975 , is limited to “citizen’s complaints,” which refer to complaints filed by private individuals against PNP members. The law distinguishes these from complaints involving internal discipline within the PNP, which are to be handled through the PNP’s own internal mechanisms. The Court found that the complaints filed by the respondent policemen and Pat. Ekid arose from their official relations as subordinates to the petitioners and pertained to the latter’s performance of their official functions, such as the issuance of transfer orders. These are matters of internal discipline and are not within the purview of the PLEB’s authority. The petitions were granted, and the PLEB was permanently enjoined from proceeding with the administrative cases (Administrative Case No. 007-92 and Administrative Case No. 042-92).