Case Digest - G.R. No. 155336

000 CHR Employees Assoc.
, represented by its AUTHOR:

President, Marcial A. Sanchez, Jr., petitioner, vs. NOTES: (if applicable)
Commission on Human Rights (CHR), respondent
[G.R. No. 155336; Nov. 25, 2004 ]
TOPIC: Judicial Review: Proper Party
PONENTE: Chico-Nazario, J.
FACTS:
1. On September 04, 1998, CHR promulgated Res. No. A98-047, where CHR adopted an upgrading and reclassification scheme
among selected positions in the Commission and it ordered its Human Resources Development Department (HRDD) to prepare the
Notice of Salary Adjustment and the other appropriate documents to support the implementation of the resolution.
2. October 19, 1998 CHR issued Res. No. A98-055 that provided for the upgrading or raising of salary grades of certain positions in
the Commission. In this resolution, CHR also said that savings under Personnel Services will be used to support the implementation of
the scheme.
3. On November 17, 1998, CHR issued Res. No. A98-062, where the CHR collapsed the vacant positions in the body to provide
additional source of funding for the said staffing modification.
4. CHR forwarded the request for approval of the staffing modification and upgrading scheme to the Department of Budget
Management (DBM), however the then DBM secretary, Benjamin Diokno, denied the request. The justifications were:
The upgrading scheme involved the elevation of the field units from division to services
In Section 78 of the General Provisions of the General Appropriations Act (GAA) FY 1998, no organizational unit or changes
in key positions shall be authorized unless provided by law or directed by the President. There is no existing law as basis for
CHRs scheme.
In Section 2 RA No. 6758, Compensation Standardization Law, the DBM is directed to establish and administer a unified
compensation and position classification system in the government. Also, the SC ruled in the case Victorina Cruz vs. Court of
Appeals, GR NO. 119155, that DBM has the sole power and discretion to administer the compensation and position
classification system of the National Government.
Though the CHR is a member of the Constitutional Fiscal Autonomy Group (CFAG), it does not have the authority to
reclassify, upgrade, and create positions without DBMs approval. CFAG members are authorized to formulate and implement
the organizational structures of their respective offices and determine the compensation, these must be within the parameters
of the Unified Position Classification and Compensation Authority under RA 6758.
5. In light of DBMs disapproval, CSC-NCR released a memorandum dated March 29, 1999, recommending to the CSC-Central
Office that the subject appointments be rejected.
6. Meanwhile the officers of petitioner, CHREA, in representation of the CHR rank and file employees, also requested the CSC-Central
Office to affirm the recommendation. Their request was denied by CSC-Central Office through a resolution and when CHREA filed a
motion of reconsideration, this was also denied. CHREA elevated the case to the Court of Appeals, but CA affirmed and validity of the
resolution of CSC-Central Office, CHREA filed a petition to the SC.
In the petition, CHREA said that the CSC-Central Office and CA were erred in approving CHRs alleged authority when DBMs
approval is indispensible for such scheme. CHREA also argued was wrong when it held that the CHR, according to the constitution,
enjoys fiscal autonomy.
7. The respondent questioned the locus standi of CHREA, considering that it not a recognized bona fide organization of its
employees nor is there anything in the records to show that its president, Marcial A. Sanchez, Jr., has the authority to sue
the CHR.
ISSUE(S): Does the petitioner have a locus standi on the case?
HELD: Yes.
CHREA has locus standi on the case since Here, the petitioner, which consists of rank and file employees of respondent
CHR, protests that the upgrading and collapsing of positions benefited only a select few in the upper level positions in the
Commission resulting to the demoralization of the rank and file employees.
RATIO: locus standi or legal standing refers to a personal and substantial interest in a case such that the party has
sustained or will sustain direct injury because of the act.
A proper party is one who has sustained or is in immediate danger of sustaining an injury as a result of the act complained.
This meets the injury test. If the CHRs scheme is found valid, potentially entails consuming of the Commissions savings
or that portion of its budgetary pie allocated for Personnel Services, from which the benefits of the employees, including
those in rank and file, are derived.
CHREA has locus standi on the case since Here, the petitioner, which consists of rank and file employees of respondent
CHR, protests that the upgrading and collapsing of positions benefited only a select few in the upper level positions in the
Commission resulting to the demoralization of the rank and file employees.
The personality of the petitioner to file this case was recognized by the CSC when it took into cognizance of CHREAs
request to affirm the recommendation of the CSC-National Capital Region Office.

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