IN RE: DESIGNATION OF JUDGE RODOLFO U.

MANZANO AS MEMBER OF THE ILOCOS

NORTE PROVINCIAL COMMITTEE ON JUSTICE
Facts: Judge Rodolfo U. Manzano sent a letter to the SC requesting that he be authorized to accept
the appointment of Gov. Rodolfo Farinas as a member of the Ilocos Norte Provincial Committee on
Justice pursuant to Presidential Executive Order No. 856.
Among the functions of the Committee are—
3.3 Receive complaints against any apprehending officer, jail warden, final or judge who may
be found to have committed abuses in the discharge of his duties and refer the same to
proper authority for appropriate action;
3.5 Recommend revision of any law or regulation which is believed prejudicial to the proper
administration of criminal justice.

Issue: Whether Judge Manzano can be authorized to accept the appointment?

Ruling: No. Under the Constitution, the members of the Supreme Court and other courts established
by law shall not be designated to any agency performing quasi- judicial or administrative
functions (Section 12, Art. VIII, Constitution).
Considering that membership of Judge Manzano in the Ilocos Norte Provincial Committee on
Justice, which discharges an administrative function, will be in violation of the Constitution, the Court
is constrained to deny his request.
This declaration does not mean that RTC Judges should adopt an attitude of monastic insensibility
or unbecoming indifference to Province/City Committee on Justice. As incumbent RTC Judges, they
form part of the structure of government. Their integrity and performance in the adjudication of cases
contribute to the solidity of such structure. As public officials, they are trustees of an orderly society.
Even as non-members of Provincial/City Committees on Justice, RTC judges should render
assistance to said Committees to help promote the laudable purposes for which they exist, but only
when such assistance may be reasonably incidental to the fulfillment of their judicial duties.

US vs. Fredd Dorr, etal.

Facts: Herein respondents were alleged to have committed an offense of writing, publishing and
circulating scurrilous libel against the Government of the U.S. and the Insular Government of
the Philippine Islands in violation of Section 8, Act 292 of the Commission.

The alleged libel was published in “Manila Freedom” issue dated 06 April 1902 as an editorial issue.
The editorial is about the appointment of rascal natives (Filipinos) to important Government positions
by the Civil Commission (CC for brevity).

Issue: Whether the Article published by the respondents is in violation of the Art. 292 for it directly
attacks the U.S. government and the Insular Government of the Phil. Island?
Ruling: No. In modern political science, the term government is defined as “the institution or
aggregate of institutions by which an independent society makes and carries out those
rules…xxx…the government is the aggregation of authorities which rule a society (administration)”.
On the other hand, the Sedition Act of 1798, the term ‘government’ is used in an abstract sense (e.q.
President, Congress), meaning the existing political system, its laws and institutions. The Court
opines that it is in this sense that the term is used in the enactment (Art. 292) under consideration.
Hence, in Art. 292, the meaning of “Insular of the Government of the Phil. Islands” is the government
as a system, however, the article in questions attacks the ‘government’ as the aggregate of public
officials who run it.
The Court ruled that the article in question contains no attack upon the governmental system
of the U.S., by which the authority of the U.S. is enforced in these Islands per se. In this case, it is
the character of men who are entrusted with the administration of the government which the
writer wants to bring disrepute due to their motives, public integrity, and private morals and wisdoms
of their policy. The publication does not constitute any seditious tendency being apparent to be in
violation of Art. 292.