Issue whether the COA has exclusive authority to audit government banks.

NO. The COA does not have the exclusive power to examine and audit government agencies. The framers of the
Constitution were fully aware of the need to allow independent private audit in the government agencies in addition to
the COA audit, as when there is a private investment in a government-controlled corporation, or when a government
corporation is privatized or publicly listed, or as in the case at bar when the government borrows money from abroad.
Distinction between career and non-career service.
Career service characterized by entrance based on merit and fitness to be determined, as far as practicable by
competitive examinations or based on highly technical qualifications; opportunity for advancement to higher career
positions and security of tenure. Non-career service characterized by entrance bases other than those of the usual tests
utilized for the career service; tenure limited to the period specified by law, or which is co-terminus with that of the
appointing authority or subject to his pleasure or which is limited to the duration of a particular project for which
purpose the employment was made.

Academic Freedom
Section 5(3) explicates an aspect of academic freedom. It recognizes the right of every citizen to study and prepare
himself for any profession of his choice. However, as already seen, there is also recognition of the right of schools to
impose admission standards. The state itself may also set admission standards. When the state, however, imposes
standards, either by law or by regulation, these standards must be reasonable and equitable in their application.
Constitutional limits on executive clemency (6)
1. cannot be granted in cases of impeachment
2. cannot be granted in cases of violation of election laws without the favorable recommendation of the
Commission on Elections
3. can be granted only after conviction by final judgment
4. cannot be granted in cases of legislative contempt
5. cannot absolve the convict of civil liability
6. cannot restore public offices forfeited
Safeguards Insuring the Independence of the Commissions (11)
1. They are constitutionally created; may not be abolished by statute.
2. Each is expressly described as independent.
3. Each is conferred certain powers and functions which cannot be reduced by statute.
4. The Chairmen and members cannot be removed except by impeachment.
5. The Chairmen and members are given a fairly long term of office of seven years.
6. The Chairmen and members may not be reappointed or appointed in an acting capacity
7. The salaries of the chairman and members are relatively high and may not be decreased during continuance in
office.
8. The Commissions enjoy fiscal autonomy.
9. Each Commission may promulgate its own procedural rules, provided they do not diminish, increase or modify
substantive rights [though subject to disapproval by the Supreme Court]
10. The Chairmen and members are subject to certain disqualifications calculated to strengthen their integrity.
11. The Commissions may appoint their own officials and employees in accordance with Civil Service Law.
National Territory
Section 1, Art. 1
The national territory comprises the Philippine archipelago, with all the islands and waters embraced therein, and all
other territories over which the Philippines has sovereignty or jurisdiction, consisting of its terrestrial, fluvial, and aerial
domains, including its territorial sea, the seabed, the subsoil, the insular shelves and other submarine areas. The waters
around, between, and connecting the islands of the archipelago, regardless of their breadth and dimensions, form part
of the internal waters of the Philippines.
Limitations of Legislative Investigation
1. In aid of legislation
2. In accordance with duly published rules of procedures
3. Rights of persons appearing in, or affected by such, inquiry shall be respected