CHREA VS CHR

Facts: CHREA filed a petition to review the decision of Court of Appeals, which affirmed
the reorganization proposed by the CHR despite the disapproval of DBM. The grounds
of the reorganization was the RA 8522 which is the GAA of 1998. The act provided for
the fiscal autonomy of all constitutional offices and the CHR is a member of (CFAG)
Although DBM did not approved of the reorganization, CSC affirmed also the scheme of
CHR.

Issue: Can the CHR lawfully implement an upgrading and reclassification of personnel
positions without the prior approval of DBM?
Ruling: No, CHR must have the approval of DBM. The petition is granted and reversed
the decision of CA. The reclassification and upgrading of position are disallowed.
Principles:
RA 6758 – Compensation and Position Classification Act of 1989
Section 2 of the act says that the DBM’s function is to establish a unified Compensation
and Position Classification
While section 4, pertains to the coverage of the act which shall apply to all positions etc,
in the government. Government refers to the executive, legislative and the Judicial and
the Constitutional Commissions.
Article IX of Constitution and Administrative Code, Chapter 5 Section 24, 26
Constitutional Commissions which shall be independent are the CSC, COMELEC and
COA only.
According to the maxim “Expressio Unius Est Exclusio Alterius” meaning that when one
or more things of a class are expressly mentioned, others of the same class are
exluded.
Being a member of the fiscal autonomy group does not vest the agency with the
authority to reclassify, upgrade, and create positions without approval of the DBM.
While the members of the Group are authorized to formulate and implement the
organizational structures of their respective offices and determine the compensation of
their personnel, such authority is not absolute and must be exercised within the
parameters of the Unified Position Classification and Compensation System established
under RA 6758 more popularly known as the Compensation Standardization Law.