GR 95818; (August, 1991) (Digest)
March 16, 2026GR 121404; (May, 2006) (Digest)
March 16, 2026G.R. No. 155336 ; November 25, 2004
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 fiscal autonomy provisions in the 1998 General Appropriations Act (R.A. No. 8522), issued Resolutions in 1998 upgrading and reclassifying various personnel positions and creating new ones. The CHR acted without prior approval from the Department of Budget and Management (DBM). The DBM subsequently disapproved the scheme, prompting the CHR Employees’ Association (CHREA) to file a complaint with the Civil Service Commission (CSC). The CSC-NCR initially ruled the resolutions invalid without DBM approval, but the CSC en banc reversed, sustaining the CHR’s authority. The Court of Appeals affirmed the CSC’s ruling, leading CHREA to elevate the case to the Supreme Court.
ISSUE
Whether the Commission on Human Rights, as a constitutionally-created office enjoying fiscal autonomy, can lawfully implement an upgrading and reclassification of personnel positions without the prior approval of the Department of Budget and Management.
RULING
No. The Supreme Court reversed the Court of Appeals and reinstated the CSC-NCR ruling, disallowing the CHR resolutions. The Court held that while the CHR enjoys fiscal autonomy, this autonomy is not absolute and must be exercised within the framework of existing laws. The power to upgrade and reclassify positions is intrinsically linked to the power to appropriate public funds and implement the national compensation and position classification plan, which is vested by law in the DBM. The special provisions in the General Appropriations Act relied upon by the CHR did not repeal or amend the general laws, such as the Administrative Code, which designate the DBM as the central authority for compensation and position classification. Fiscal autonomy grants the CHR independence in the allocation and utilization of its funds but does not exempt it from the DBM’s oversight in ensuring uniformity and standardization in government compensation. The DBM’s disapproval, therefore, was a valid exercise of its mandated function.