G.R. No. 181704 December 6, 2011 Villarama, Jr., J. FACTS OF THE CASE Republic Act No. 9335, also known as the Attrition Act 2005 was enacted by Congress and signed by GMA. It aims to optimize revenue-generation capability and collection of the Bureau of Customs. Also, it encourages employees to increase their revenues through a reward system via the Rewards and Incentives Fund and Revenue Performance Board. The Implementing Rules and Regulations (IRR) was then enacted by Congress through its Joint Congress Oversight Committee. Petitioner BOC Employees Association (BOCEA) is composed of rank-and-file employees of the Bureau of Customs. In fulfillment of the mandate of R.A. 9335, high officials of BOC started to disseminate Collection District Performance Contracts (Performance Contracts) to lower ranking officials and rank-and-file employees. These contracts contain the following: (a) failure to meet the quota would hold the employee liable under the Act, and (b) the employees are required to execute the contract and they are directed to accept their individual targets. Petitioners assail the Act on the ground that the means employed are unreasonable to achieve its objectives. They argue that, the government, in shifting the burden of revenue generation to its employees, is unduly oppressive. On the other hand, respondents argue that there is a valid and substantial distinction when it classified BOC (and BIR) employees as public officers. Primarily tasked with revenue-generation, it is essentially involved with the inherent government power of taxation. Further, the performance contracts serve as a notice for the required target the employees are required to meet. With regard to the decisions with regard to the results of the performance evaluations and its consequences, respondents argue that there is nothing in the law that prevents them to question or appeal the said decision. ISSUE/S W/N the R.A. 9335 violates the due process clause and the equal protection clause HELD/RATIO R.A. 9335 lays down reasonable guidelines for the removal of employees in full consideration of all the relevant factors that affect individual collection. Further, the action for removal is subject to existing civil service laws, rules, and regulations. Therefore, it is compliant of the essential requirements of due process. On the other hand, the law concerns the BIR and the BOC only because they have the common function of generating revenue for the national government through the collection of taxes, customs, duties, fees, and charges. As part of the instrumentalities under the Department of Finance, they perform one of the most important functions of government: taxation. Therefore, there exists substantial distinctions and that the distinctions are germane and related to the purpose of the law. Prepared by: Antonio Dominic G. Salvador