Professional Documents
Culture Documents
Chrea Vs CHR
Chrea Vs CHR
ISSUE: Can the CHR validly implement an upgrading, SEC. 3. Powers and Functions. – The Department of
reclassification, creation, and collapsing of plantilla Budget and Management shall assist the President in the
positions in the Commission without the prior approval preparation of a national resources and expenditures
of the Department of Budget and Management? budget, preparation, execution and control of the
National Budget, preparation and maintenance of
accounting systems essential to the budgetary process,
HELD: the petition is GRANTED, the Decision of the achievement of more economy and efficiency in the
CA and its are hereby REVERSED and SET ASIDE. The management of government operations, administration
ruling CSC-National Capital Region is REINSTATED. of compensation and position classification systems,
The 3 CHR Resolutions, without the approval of the assessment of organizational effectiveness and review
DBM are disallowed. and evaluation of legislative proposals having budgetary
or organizational implications.
1. RA 6758, An Act Prescribing a Revised Compensation
and Position Classification System in the Irrefragably, it is within the turf of the DBM Secretary to
Government and For Other Purposes, or the Salary disallow the upgrading, reclassification, and creation of
Standardization Law, provides that it is the DBM that additional plantilla positions in the CHR based on its
shall establish and administer a unified Compensation finding that such scheme lacks legal justification.
and Position Classification System.
Neither does the fact that the CHR was admitted as a Further, the personality of petitioner to file this case was
member by the Constitutional Fiscal Autonomy Group recognized by the CSC when it took cognizance of the
(CFAG) ipso facto clothed it with fiscal autonomy. Fiscal CHREA’s request to affirm the recommendation of the
autonomy is a constitutional grant, not a tag obtainable CSC-National Capital Region Office. CHREA’s
by membership. personality to bring the suit was a non-issue in the CA
when it passed upon the merits of this case. Thus,
neither should our hands be tied by this technical
We note with interest that the special provision under concern. Indeed, it is settled jurisprudence that an issue
Rep. Act No. 8522, while cited under the heading of the that was neither raised in the complaint nor in the court
CHR, did not specifically mention CHR as among those below cannot be raised for the first time on appeal, as to
offices to which the special provision to formulate and do so would be offensive to the basic rules of fair play,
implement organizational structures apply, but merely justice, and due process.
2. In line with its role to breathe life into the policy
behind the Salary Standardization Law of “providing
equal pay for substantially equal work and to base
differences in pay upon substantive differences in duties
and responsibilities, and qualification requirements of
the positions,” the DBM, in the case under review, made
a determination, after a thorough evaluation, that the
reclassification and upgrading scheme proposed by the
CHR lacks legal rationalization.