FACTS:

The case involves a petition questioning whether the City Council of Manila still has the power to appoint council officers and employees under Republic Act No. 409 or if the power is now vested with the City Mayor pursuant to Republic Act No. 5185 and Batas Blg. 337. The Vice-Mayor of Manila submitted the appointments of nineteen officers and employees in the Executive Staff of the City Council of Manila to the Civil Service Commission. The City Budget Officer sought a recommendation from the City Legal Officer on the proper appointing authority, which the City Legal Officer opined to be the City Mayor. The Civil Service Commission, however, ruled that the City Council is the proper appointing authority based on Section 15 of Republic Act No. 409. The petitioner contends that Section 15 of Republic Act No. 409 has been repealed by Republic Act No. 5185. The case was brought as a "direct appeal" from the resolution of the Civil Service Commission, but the Supreme Court accepted the petition as a petition for certiorari under Rule 65 due to the importance of the public interest involved. The case discusses the principles of statutory construction, including the principle that a special law prevails over a general law and the disfavor of repeals by implication. The Court ultimately finds no grave abuse of discretion committed by the Civil Service Commission and dismisses the petition.

ISSUES:

1. Whether the City Council of Manila still has the power to appoint Council officers and employees under Republic Act No. 409, or whether the power is now vested with the City Mayor pursuant to Republic Act No. 5185 and Batas Blg. 337.

RULING:

1. The City Council of Manila still has the power to appoint Council officers and employees under Republic Act No. 409. The Supreme Court held that a special law, such as Republic Act No. 409, prevails over a general law, such as Republic Act No. 5185 and Batas Blg. 337. Repeals of laws by implication are not favored, and there must be a clear repugnancy between the statutes to hold one as repealing the other. The Court further noted that the provisions of Republic Act No. 5185 and Batas Blg. 337 were intended to transfer the power of appointment over local officials and employees from the President to the local governments and to highlight the autonomy of local governments, but not to deprive the City Council of its appointing power granted by existing statute. Therefore, the City Council of Manila still has the authority to appoint Council officers and employees.

PRINCIPLES:

• Special laws prevail over general laws.

• Repeals of laws by implication are disfavored.

• The transfer of the power of appointment over local officials and employees from the President to the local governments is meant to highlight the autonomy of local governments.