Saturday, July 14, 2012

Dominador Aytona vs. Andres Castillo


January 19, 1962 4SCRA 1
Ponente: CJ Bengzon


Facts: December 19, 1961, Aytona was appointed as ad interim Governor of Central Bank and took oath and office on the same date. Noon of December 30, 1961 President elect D. Macapagal assumed office and subsequently on December 31, 1961 issued Order No. 2, cancelling all ad interim appointments made by the previous Chief of State. On the 1st day of January 1962, Castillo was appointed by the incumbent president as Governor of Central Bank therefor replacing the ad interim appointee Aytona, and the former qualified immediately. Aytona instituted a qou warranto proceeding challenging the right of Castillo to exercise his right to the said post.

Issue: Whether or not the new president has the power to cancel all ad interim appointments made by the previous president after they have all qualified?

Held: To quote “We are informed, it is Malacañan's practice — which we find to be logical — to submit ad interim appointments only when the Commission on Appointments is in session. One good reason for the practice is that only those who have accepted the appointment and qualified are submitted for confirmation. Nevertheless, this time, Malacañan submitted its appointments on the same day they were issued; and the Commission was not then in session; obviously because it foresaw the possibility that the incoming President would refuse to submit later the appointees of his predecessor. As a result, as already adverted to, some persons whose names were submitted for confirmation had not qualified nor accepted their appointments.” 

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