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DOCTRINES:
1. Real fiscal autonomy covers the grant to the Judiciary of the authority to use and dispose of its funds and
properties at will, free from any outside control or interference (Bengzon vs Drilon).
2. Thus, under the guarantees of the Judiciarys fiscal autonomy and its independence, the Chief Justice and
the Court En Banc determine and decide the who, what, where, when and how of the privileges and
benefits they extend to justices, judges, court officials and court personnel within the parameters of the
Courts granted power; they determine the terms, conditions and restrictions of the grant as grantor.
3. One of the most important aspects of judicial independence is the constitutional grant of fiscal autonomy.
Just as the Executive may not prevent a judge from discharging his or her judicial duty (for example, by
physically preventing a court from holding its hearings) and just as the Legislature may not enact laws
removing all jurisdiction from courts, the courts may not be obstructed from their freedom to use or
dispose of their funds for purposes germane to judicial functions
FACTS: This is an administrative matter that stemmed from 2 memoranda submitted by Atty. Eden T. Candelaria
(Deputy Clerk of Court & Chief Administrative Officer, Officer of Administrative Services) to the office of the
Chief Justice.
Memoranda asked the Court to determine the proper formula to be used in computing the appraisal value
that justices have to pay to acquire government properties that they used during their tenure.
COA:
COA issued an opinion in June 2010 which found the underpayment amounting to Php 221,021.50 that
resulted when 5 retired SC justices purchased from SC the personal properties assigned to them during their
incumbency.
Items purchased include cars of various models (Toyota Camry and Toyota Grandia) and a Sony TV Set.
Justices involved: CJ Panganiban; Assoc. Justices Reyes, Gutierrez, Azcuna, & Austria-Martinez.
The COA attributed this underpayment to the use of (formula) Constitutional Fiscal Autonomy Group
(CFAG) when it should have applied the formula found in COA Memorandum No. 98-569-A dated August
5, 1998.
Office of the Administrative Services:
Atty. Candelaria recommended that the Court advise the COA to respect the in-house computation based
on the CFAG formula, because even COA upheld CFAG in 2 previous instances.
More importantly, the Constitution itself grants the Judiciary fiscal autonomy in the handling of its budget
and resources. Full autonomy, among others, contemplates the guarantee of full flexibility in the allocation
and utilization of the Judiciarys resources, based on its own determination of what it needs.
To allow the COA to substitute the Courts policy in the disposal of its property would be tantamount to an
encroachment into this judicial prerogative.
ISSUE: WON the use of the CFAG formula (despite COAs opinion in the negative) is legal and valid (YES)
HOLDING:
The Court stated that COAs authority to conduct post-audit examinations on constitutional bodies granted
fiscal autonomy (Section 2(1), Article IX-D of Consti) must be read not only in light of SCs fiscal
autonomy [related to topic so point B below is more important] but also in relation with the constitutional
provisions on judicial independence (and separation of powers).
A. Separation of powers & judicial independence
o In Angara v. Electoral Commission, the Court explained the principle of separation of powers. It
held that the separation of powers is a fundamental principle in our government and is obtained not
through express provision but by actual division in our Constitution.
o SC: The Judiciary has unique circumstances and its judicial independence can be broken down into
two distinct concepts:
a. Decisional independence - refers to a judges ability to render decisions free from political
or popular influence based solely on the individual facts and applicable law.
b. Institutional independence - describes the separation of the judicial branch from the
executive and legislative branches of government (collective independence of the judiciary
as a body).
o A truly independent judiciary is possible only when both concepts of independence are preserved.
o The Constitution expressly prohibits Congress from depriving SC of its jurisdiction (Section 5
Article VII).
DISPOSITIVE: The in-house computation of the appraisal value made by the Property Division (Office of
Administrative Services) based on CFAG is CONFIRMED to be legal and valid.