2.

Topic:

Civil Liberties Union vs Executive Secretary, 194 SCRA 317

Interpretation & Construction of Constitution

FACTS:
Petitioners questioned the validity of Executive Order No. 284 (EO No. 284),
issued by former President Corazon Aquino which allowed members of the
Cabinet, their Undersecretaries and Assistant Secretaries to hold other
government positions in addition to their primary positions.
Petitioners argued that the provisions of EO 284 were in direct contrast with
Section 13, Article VII of the Constitution. According to the petitioners, the
only exceptions against holding any other office or employment in
government are those provided in the Constitution namely: 1) the Vice
President may be appointed as a Cabinet member under Section 3(2) of
Article VII; 2) The Secretary of Justice is and ex-officio of the Judicial and Bar
Council by virtue of Section 8, Article VIII.
ISSUE:
W/N the EO No. 284 is constitutional?

HELD:
No, it is unconstitutional.
The Court held that the legislative intent of the Constitutional
provisions is to prevent government officials from holding multiple positions
in the government for self-enrichment which is a betrayal of public trust.
According to the Court, in construing the Constitution, one should bear
in mind the object sought to be accomplished by its adoption, and
the evils, if any, sought to be prevented or remedied.
In this case, the Court ruled the EO to be unconstitutional for violating the
express mandate provided by the Constitutional provisions (Sec. 13, Art. VII
and Sec. 8, Art. VIII). The Constitution, the fundamental law of the
land, shall reign supreme over any other statute. When there is
conflict, it shall be resolved in favor of the highest law of the land.