E. Blaquera, et al. v. Alcasid G.R no.

109406, September 11, 1998

Control means “the power of an officer to alter or modify or set a side what a subordinate
officer had done in the performance of his duties and substitute the judgment of the former for
that of the latter.” It has been held that “[t]he President can, by virtue of his power, review,
modify, alter or nullify any action, or decision, of his subordinate in the executive departments,
bureaus, or offices under him. He can exercise this power motu proprio without need of any
appeal from any party.”

F. Dadole, et al. v. COA G.R no. 125350, December 3, 2002

“… In administrative law, supervision means over seeing or the power or authority of an
officer to see that subordinate officers perform their duties. If the latter fail or neglect to fulfill
them, the former may take such action or step as prescribed by law to make them perform their
duties. Control, on the other hand, means the power of an officer to alter or modify or nullify or
set aside what a subordinate officer ha[s] done in the performance of his duties and to substitute
the judgment of the former for that of the latter.”

Clearly then, the President can only interfere in the affairs and activities of a local
government unit if he or she finds that the latter has acted contrary to law. This is the scope of
the President’s supervisory powers over local government units.

Sec. 20 Residual Powers. – Unless Congress provides otherwise, the President shall
exercise such other power and functions vested in the President which are provided for under
the laws and which are not specifically enumerated above or which are not delegated by the
President in accordance with law.

This provision speaks of such other power vested in the President under the law. What
law then gives him the power to reorganize the national government? It is the Presidential Decree
No. 1772 which amended Presidential Decree No. 1416. These decrees expressly grant the
President of the Philippines the continuing authority to reorganize the national government,
which includes the power to group, consolidate bureaus and agencies, to abolish offices, to
transfer functions, to create and classify functions, services and activities and to standardize
salaries and materials. The validity of these two decrees in unquestionable. The 1987 Philippine
Constitution clearly provides that “at all laws, decrees, executives orders, proclamations, letters
of instructions and other executive issuances not inconsistent with this Constitution shall remain
operative until amended, repealed or revoked.” So far, there is yet no law amending or repealing
said decrees.