Rendered in the Exercise of Quasi-Judicial Functions | CONSTITUTIONAL COMMISSIONS

In the realm of Philippine Political Law and Public International Law, specifically under the topic of Constitutional Commissions and their powers rendered in the exercise of quasi-judicial functions, there are key concepts to be examined. Here is a detailed analysis of this legal framework:

IV. CONSTITUTIONAL COMMISSIONS

The Constitutional Commissions are independent bodies created by the 1987 Philippine Constitution to ensure transparency, fairness, and accountability in various aspects of governance. These Commissions perform vital roles in governmental functions, often balancing the executive, legislative, and judicial branches.

There are three Constitutional Commissions in the Philippines:

  1. Commission on Audit (COA)
  2. Civil Service Commission (CSC)
  3. Commission on Elections (COMELEC)

G. Rendered in the Exercise of Quasi-Judicial Functions

The Constitutional Commissions not only have administrative functions but also quasi-judicial powers. Quasi-judicial functions involve the capacity to hear and decide on cases, impose penalties, and settle disputes involving parties under their jurisdiction. This is similar to the judiciary but within a specialized scope of law and jurisdiction.

Let's break this down by discussing the quasi-judicial powers of each Commission:


1. Commission on Audit (COA)

The COA is responsible for auditing all government revenues, expenditures, and the use of public funds. It has quasi-judicial functions in the sense that it has the power to:

  • Adjudicate audit disallowances: COA can review and resolve controversies regarding the legality of the use of public funds. If a government office is found to have used funds improperly, COA can issue an audit decision that disallows the expenditure.
  • Appeals on audit decisions: If a party disagrees with COA’s decision (for instance, a government agency or a private contractor dealing with the government), the party may appeal within COA, and the decision may be elevated to the Supreme Court on certiorari if COA’s final decision is unfavorable.

Relevant Cases and Decisions:

  • COA’s decisions are binding unless reversed by a higher judicial authority (such as the Supreme Court). However, COA decisions carry weight in all fiscal matters involving public funds and accountability.

2. Civil Service Commission (CSC)

The CSC is tasked with the management of the Philippine bureaucracy, ensuring merit and fitness in government appointments and employment. It exercises quasi-judicial powers in handling:

  • Personnel disputes: CSC has the authority to hear administrative cases concerning government employees, including dismissal, suspension, demotion, and other personnel actions.
  • Review of administrative decisions: The CSC can review decisions made by appointing authorities in government agencies. It acts as the final arbiter in disputes concerning employment, tenure, and disciplinary actions in the civil service.
  • Appeals: Decisions of the CSC in its quasi-judicial capacity may be appealed to the Court of Appeals via a Rule 43 petition or directly to the Supreme Court in cases involving questions of law.

Examples of Quasi-Judicial Decisions:

  • Rulings on administrative discipline cases involving government employees accused of misconduct or inefficiency.
  • Decisions affecting the appointment, promotion, or discipline of civil servants can be reviewed through a quasi-judicial process, and its final rulings may have the force and effect of law unless overturned by the courts.

3. Commission on Elections (COMELEC)

The COMELEC has both administrative and quasi-judicial functions, with the latter relating primarily to the conduct of elections and electoral disputes. COMELEC’s quasi-judicial powers include:

  • Resolution of electoral disputes: COMELEC can resolve pre-election disputes (e.g., issues on qualifications of candidates, campaign violations) and post-election controversies (e.g., electoral protests). It exercises original jurisdiction over contests relating to the election, returns, and qualifications of elective regional, provincial, and city officials.
  • Disqualification and cancellation of candidacies: COMELEC has the authority to disqualify candidates for violations of election laws or ineligibility, with its decisions having binding effect unless appealed to the Supreme Court.
  • Contempt powers: In its quasi-judicial role, COMELEC can cite parties for contempt if they disobey its orders or disrupt its proceedings.

Judicial Review: Decisions of the COMELEC may be appealed to the Supreme Court in cases involving grave abuse of discretion or questions of law.

Relevant Cases:

  • COMELEC's rulings on the validity of election returns or qualifications of candidates are binding and have a direct impact on the election results, but they may be questioned in the Supreme Court.

Quasi-Judicial Functions: General Principles

  1. Finality of Decisions: Decisions rendered by Constitutional Commissions in the exercise of quasi-judicial functions are final and executory, subject only to judicial review by higher courts (typically the Court of Appeals or Supreme Court).

  2. Substantial Evidence Standard: The quasi-judicial decisions of these Commissions are based on a “substantial evidence” standard, which means that the amount of evidence required to justify a decision is less than that required in judicial proceedings (where a "preponderance of evidence" or "proof beyond reasonable doubt" may be needed).

  3. Appeals Process: While these bodies have final authority within their specialized fields, their quasi-judicial decisions can be subject to review by higher courts, particularly on grounds of grave abuse of discretion, or if the ruling involves questions of law or constitutionality.

  4. Judicial Review: Under Article VIII, Section 1 of the 1987 Constitution, judicial power includes the duty of the courts to settle actual controversies involving rights that are legally demandable and enforceable, and to determine whether there has been a grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the government, including Constitutional Commissions exercising quasi-judicial functions.


Conclusion

The Constitutional Commissions of the Philippines, namely COA, CSC, and COMELEC, are vested with significant quasi-judicial powers that allow them to make binding rulings within their respective areas of responsibility. These decisions may only be overturned or modified by the judiciary under specific circumstances, particularly when there is a question of law or when grave abuse of discretion is alleged. Their rulings play a crucial role in maintaining checks and balances in the government and in ensuring that public resources are properly managed, that the civil service is free from political interference, and that elections are fair and just.