G.R. No. L-8062 July 18, 1955
JOSE QUINTOS, plaintiff-appellee, vs. HONORABLE ARSENIO H. LACSON, ET AL., defendants-appellants.

FACTS

Plaintiff-appellee Jose Quintos was appointed patrolman in the Manila Police Department in December 1945 and was promoted to detective on December 16, 1947. On July 3, 1952, Manila Mayor Arsenio H. Lacson, through a letter, dismissed Quintos and four other detectives for “lack or loss of confidence.” Quintos filed a complaint for injunction in the Court of First Instance of Manila to annul this dismissal and prevent its execution. The lower court issued a preliminary injunction and later rendered judgment in favor of Quintos, granting a permanent injunction to prevent his dismissal without a prior investigation under Republic Act No. 557 , ordering his reinstatement, and directing payment of back salaries. Mayor Lacson and Chief of Police Dionisio S. Ojeda appealed directly to the Supreme Court.

ISSUE

The issue is the validity of the summary dismissal of a Manila city detective under Executive Order No. 264, in view of the provisions of Republic Act No. 557 .

RULING

The Supreme Court affirmed the lower court’s decision. It held that city detectives are members of the police force, and the manner of their dismissal is governed by Republic Act No. 557 . The Court ruled that Executive Order No. 264, Series of 1940, which declared the position of detective as confidential, had been repealed by Republic Act No. 557 insofar as it conflicted with the latter. Following its previous rulings in cases such as Olegario vs. Lacson, Mission vs. Del Rosario, Abella vs. Rodriguez, Palamine vs. Zagado, and Uy vs. Rodriguez, the Court held that a detective, unless appointed under a temporary status, may not be dismissed except in accordance with the investigation and hearing procedures provided in Republic Act No. 557 . The Court declined to review its prior rulings, stating that its interpretation was correct and that any perceived issues with the laws should be addressed to the Legislature.