ConstiLaw1
Module 2: Separation of Powers / Checks and Balances
IN RE: Designation of Judge Rodolfo U. Manzano as member of the Ilocos Norte
Provincial Committee on Justice
A.M. No. 88-7-1861-RTC October 5, 1988
FACTS:
Judge Rodolfo U. Manzano was designated by the Ilocos Norte Governor Rodolfo C.
Farinas to be a member of the Ilocos Norte Provincial Committee on Justice. Before
accepting the appointment, he wrote a letter to the Supreme Court to ask for
permission and official resolution to accept the designation.
The SC examined the executive order (EO No. 856) related to the creation of the
Provincial/City Committees on Justice and found out that among the functions of the
Committee were:
3.3 Receive complaints against any apprehending officer, jail warden, final or judge
who may be found to have committed abuses in the discharge of his duties and refer
the same to proper authority for appropriate action;
3.5 Recommend revision of any law or regulation which is believed prejudicial to the
proper administration of criminal justice.
ISSUE:
Should Judge Manzano’s request be granted?
RULING:
No. The Ilocos Norte Provincial Committee on Justice discharges administrative
functions and under the Constitution (Section 12, Art VIII, Constitution), members of
the Supreme Court and other courts should not be designated to any agency
performing quasi-judicial or administrative functions.
…Even as non-members of Provincial/City Committees on Justice, RTC judges
should render assistance to said Committees to help promote the laudable purposes
for which they exist, but only when such assistance may be reasonably incidental to
the fulfilment of their judicial duties…