GR 161081; (May, 2005) (Digest)
G.R. No. 161081 ; May 10, 2005
RAMON M. ATIENZA, in his capacity as Vice-Governor of the Province of Occidental Mindoro, petitioner, vs. JOSE T. VILLAROSA, in his capacity as Governor of the Province of Occidental Mindoro, respondent.
FACTS
Petitioner Ramon M. Atienza, Vice-Governor, and respondent Jose T. Villarosa, Governor, of Occidental Mindoro were in dispute over administrative control. The Governor issued a Memorandum dated June 25, 2002, directing that all Purchase Orders for supplies and equipment for the Sangguniang Panlalawigan (SP) must be approved by him as the local chief executive. The Vice-Governor objected, citing the principle of separation of powers between the executive and legislative branches at the local level. Subsequently, the Governor issued another Memorandum dated July 1, 2002, terminating all casual/job order employment contracts signed by the Vice-Governor for the SP, deeming them unauthorized, and allowing only a limited number of such employees to be appointed upon his approval.
ISSUE
The core issue was whether the Governor, as the local chief executive, could validly require his approval on all Purchase Orders for the SP and unilaterally terminate the appointments of casual/job order employees made by the Vice-Governor for the legislative body.
RULING
The Supreme Court ruled in favor of the Vice-Governor and declared the Governor’s memoranda null and void. The legal logic rests on the principle of separation of powers enshrined in the Local Government Code (LGC). The Court emphasized that the province’s executive and legislative branches are separate and co-equal. The SP, as the legislative body, possesses fiscal autonomy. The authority to approve Purchase Orders for its supplies and equipment is an internal legislative function necessary for its independence, not an executive function requiring the Governor’s approval. The Court cited Section 361 of the LGC, which requires the local chief executive’s approval only for requisitions of supplies to be carried in stock, not for ordinary office supplies for a specific branch. Regarding personnel, the Vice-Governor, as the presiding officer of the SP, has the authority to hire casual or temporary employees for the legislative body’s day-to-day operations. The Governor’s act of terminating these appointments and imposing a quota constituted an unlawful intrusion into the SP’s autonomy to determine its own staffing needs. The memoranda effectively undermined the SP’s independence, violating the LGC’s design for a balanced local government structure.