G.R. No. 155336 ; July 21, 2006
COMMISSION ON HUMAN RIGHTS EMPLOYEES’ ASSOCIATION (CHREA), Represented by its President, MARCIAL A. SANCHEZ, JR., petitioner, vs. COMMISSION ON HUMAN RIGHTS, respondent.

FACTS

The Commission on Human Rights (CHR), invoking special provisions in the 1998 General Appropriations Act (R.A. No. 8522) applicable to constitutional offices enjoying fiscal autonomy, promulgated resolutions adopting a staffing modification and upgrading scheme. This involved creating new positions, upgrading salary grades, and collapsing vacant positions, all to be funded from its savings. The CHR forwarded the scheme to the Department of Budget and Management (DBM) for approval. DBM Secretary Benjamin Diokno denied the request, asserting that the CHR must comply with the Salary Standardization Law and that its fiscal autonomy did not exempt it from DBM review and approval of such compensation and position classification plans. The CHR nevertheless implemented the scheme, leading to a legal challenge.

ISSUE

Whether the Commission on Human Rights, as a constitutional body, enjoys full fiscal autonomy such that it can unilaterally implement salary adjustments and reclassification schemes without the approval of the Department of Budget and Management.

RULING

The Supreme Court partially granted the CHR’s motion for reconsideration, modifying its earlier decision. The Court clarified that the CHR enjoys a limited form of fiscal autonomy. This autonomy entitles it to the automatic and regular release of its approved annual appropriations without need for further action from the Executive Branch, ensuring its independence. However, this autonomy is not absolute concerning compensation and position classification. The Court emphasized that the constitutional grant of fiscal autonomy to certain bodies like the Constitutional Commissions is explicit, while the CHR’s autonomy is statutory and implied from its constitutional functions. Consequently, the CHR remains bound by laws of general application, particularly the Salary Standardization Law. The DBM, by mandate, possesses the technical expertise to ensure uniform and equitable compensation across the government. Therefore, while the CHR can initiate reorganization and reclassification plans using its savings, the implementation of such plans, especially concerning salary rates and benefits, must conform to standardization laws and is subject to DBM approval to maintain national compensation consistency. The CHR’s resolutions were thus invalid without such approval.