GR 157286; (June, 2006) (Digest)
G.R. No. 157286 ; June 16, 2006
THE PUBLIC SCHOOLS DISTRICT SUPERVISORS ASSOCIATION (PSDSA), et al., Petitioners, vs. HON. EDILBERTO C. DE JESUS, Department Secretary, THE DEPARTMENT OF EDUCATION, and THE DEPARTMENT OF BUDGET AND MANAGEMENT, Respondents.
FACTS
Petitioners, the Public Schools District Supervisors Association (PSDSA), filed a Petition for Prohibition and Mandamus. They sought to declare unconstitutional specific provisions of Department of Education Order No. 1, Series of 2003, which implemented Republic Act No. 9155 (the Governance of Basic Education Act of 2001). Concurrently, they prayed for a writ of mandamus to compel the Department of Education and the Department of Budget and Management to upgrade their salary grade from SG 19 to SG 24. The petitioners argued that the new law and its implementing rules unjustly diminished their duties, responsibilities, and rank, warranting a higher salary grade.
The antecedent facts reveal that RA 9155 was enacted to decentralize governance and redefine roles within the Department of Education. Prior to the law, district supervisors exercised broad supervisory and administrative functions. Under the new framework, the law explicitly limited the role of schools district supervisors to providing professional and instructional advice, support, and curricula supervision. Administrative and managerial authority over school personnel, physical, and fiscal resources was transferred to school principals, who were designated as school heads.
ISSUE
The core issue is whether the petitioners have a clear legal right to a writ of mandamus compelling the upgrading of their salary grade from SG 19 to SG 24.
RULING
The Supreme Court DENIED the petition. The Court held that mandamus is a remedy only to compel the performance of a ministerial duty, not a discretionary one. The determination and classification of positions, including the assignment of salary grades, is a function lodged by law to the Department of Budget and Management. This function involves the exercise of discretion and technical expertise in evaluating the duties, responsibilities, and qualification standards of a position.
The legal logic is anchored on the principle of separation of powers and the nature of mandamus. The Court cannot substitute its judgment for the administrative discretion of the DBM. Furthermore, the reclassification of the district supervisors’ position was a direct consequence of the valid enactment of RA 9155, which lawfully redefined and limited their functions. Since their administrative and managerial powers were statutorily removed and vested in school principals, the claim that their positions were equivalent to those with SG 24 lost its basis. The petitioners failed to establish a clear and unmistakable right to the demanded salary upgrade, as no law or regulation mandates such an automatic reclassification. The implementation of RA 9155 through the challenged department order was a valid exercise of executive rule-making power.