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On March 10, 1992, the President Cory promoted fifteen (15) respondent police officers
by appointing them in a permanent capacity to the Philippine National Police (PNP) with the
rank of Chief Superintendant to Director. Pedro G. Sistoza was one of the officers. Their names
were not submitted to the Commission on Appointments (CA).

Petitioner Jesulito A. Manalo brought a petition assailing the legality of aforementioned
appointments and the disbursements for their salaries and other emoluments authorized by
Secretary Salvador M. Enriquez III of the Department of Budget and Management. He contends
that there should be confirmation from the CA considering that the PNP is akin to the Armed
Forces of the Philippines where the Constitution in Sec 16, of Article 7 specifically requires:

“The President shall nominate and, with the consent of the Commission on
Appointments, appoint… officers of the armed forces from the rank of colonel or naval captain,
and other officers whose appointments are vested in him in this Constitution.”


Whether or not the PNP appointments must be confirmed by the CA to be valid.


No. The appointments are valid even without the CA consent. Police force is different
from and independent from the armed forces and the ranks in the military are not similar to those
in the PNP (that no element of it shall be military nor shall any position be occupied by active
members of the Armed Forces of the Philippines, Sec 2 RA 6975). Therefore the directors and
chief superintendents appointed do not fall under the category of appointments that need
confirmation from the CA it falls under the Second (2 nd) sentence of the Sec 16 of Article 7 of the
Constitution stating “...He (the President) shall also appoint all other officers of the Government
whose appointments are not otherwise provided for by law, and those whom he may be
authorized by law to appoint.”