CASES ON RULE-MAKING POWER

People v. Vera

TEST OF UNDUE DELEGATION – In testing whether a statute constitutes an undue delegation of legislative power
or not, it is usual to inquire whether the statute was complete in all its terms and provisions when it left the
hands of the legislature so -that nothing was left to the judgment of any other appointee or delegate of the
legislature. In United States vs. Ang Tang Ho {[1922], 43 Phil., 1}, the Supreme Court adhered to the foregoing
rule. The general rule, however, is limited by another rule that to a certain extent matters of detail may be left
to be filled in by rules and regulations to be adopted or promulgated by executive officers and administrative
boards. As a rule, an act of the legislature is incomplete and hence invalid if it does not lay down any rule or
definite standard by which the administrative board may be guided in the exercise of the discretionary powers
delegated to it.

Maceda v. Macaraig

For a valid delegation of power, the “standard” required need not be spelled out specifically, it could be implied
from the policy and purpose of the act considered as a whole. — A reading of Section 3 of said law shows that
it set the policy to be the greater national interest. The standards of the delegated power are also clearly
provided for. The required “standard” need not be expressed. In Edu vs. Ericta and in De la Llana vs. Alba, this
Court held: “The standard may be either express or implied. If the former, the non-delegated objection is easily
met. The standard though does not have to be spelled out specifically. It could be implied from the policy and
purpose of the act considered as a whole.” In People vs. Rosenthal the broad standard of “public interest” was
deemed sufficient. In Calalang vs. Williams, it was “public welfare” and in Cervantes vs. Auditor General, it was
the purpose of promotion of “simplicity, economy and efficiency.” And, implied from the purpose of the law as
a whole, “national security” was considered sufficient standard and so was “protection of fish-fry or fish eggs.”

The powers of the FIRB are merely recommendatory; Exec. Order 93 does not provide for a genuine delegation
of power in favor of the FIRB, because the acts of the latter, are still, subject to approval by the President. –
Parenthetically, on the issue of the constitutional validity of Executive Order No. 93, insofar as it “delegates” the
power to restore exemptions to the FIRB, I hold that in the first place, Exective Order No. 93 makes no delegation
at all. As the majority points out, “[u]nder Section 1(f) of Executive Order No. 93, aforestated, such tax and duty
exemptions extended by the FIRB must be approved by the President.” Hence, the FIRB does not exercise any
power—and as I had held, its powers are merely recommendatory—and it is the President who in fact exercises
it. It is true that Executive Order No. 93 has set out certain standards by which the FIRB, as a reviewing body,
may act, but I do not believe that a genuine delegation question has arisen because precisely, the acts of the
Board are subject to approval by the President, in the exercise of her legislative powers under the Freedom
Constitution.

Rabor v. CSC

Test of a Valid Subordinate Legislation; In subordinate, delegated rule-making by administrative agencies, all
that may be reasonably demanded is a showing that the delegated legislation consisting of administrative
regulations are germane to the general purposes projected by the governing or enabling statute.-

Clearly, therefore, Cena when it required a considerably higher degree of detail in the statute to be implemented,
went against prevailing doctrine. It seems clear that if the governing or enabling statute is quite detailed and
specific to begin with, there would be very little need (or occasion) for implementing administrative regulations.
It is, however, precisely the inability of legislative bodies to anticipate all (or many) possible detailed situations
in respect of any relatively complex subject matter, that makes subordinate, delegated rule-making by
administrative agencies so important and unavoidable. All that may be reasonably demanded is a showing that
the delegated legislation consisting of administrative regulations are germane to the general purposes projected
by the governing or enabling statute. This is the test that is appropriately applied in respect of Civil Service
Memorandum Circular No. 27, Series of 1990, and to this test we now turn.
ABAKADA Guro Partylist v. Purisima

To determine the validity of delegation of legislative power, it needs the following: (1) the completeness test
and (2) the sufficient standard test. A law is complete when it sets forth therein the policy to be executed,
carried out or implemented by the delegate. It lays down a sufficient standard when it provides adequate
guidelines or limitations in the law to map out the boundaries of the delegate’s authority and prevent the
delegation from running riot. To be sufficient, the standard must specify the limits of the delegate’s authority,
announce the legislative policy and identify the conditions under which it is to be implemented.

Gutierrez v. DBM

It is a settled rule that publication is required as a condition precedent to the effectivity of a law to inform the
public of its contents before their rights and interests are affected by the same. Administrative rules and
regulations must also be published if their purpose is to enforce or implement existing law pursuant also to a
valid delegation.

Nonetheless, as previously discussed, the integration of COLA into the standardized salary rates is not
dependent on the publication of CCC 10 and NCC 59. This benefit is deemed included in the standardized salary
rates of government employees since it falls under the general rule of integration—"all allowances."

Board of Trustees v. Velasco

Not all rules and regulations adopted by every government agency are to be filed with the UP Law Center. Only
those of general or of permanent character are to be filed. According to the UP Law Centers guidelines for
receiving and publication of rules and regulations, interpretative regulations and those merely internal in nature,
that is, regulating only the personnel of the Administrative agency and not the public, need not be filed with the
UP Law Center. Resolution No. 372 was about the new GSIS salary structure, Resolution No. 306 was about the
authority to pay the 2002Christmas Package, and Resolution No. 197 was about the GSIS merit selection and
promotion plan. Clearly, the assailed resolutions pertained only to internal rules meant to regulate the
personnel of the GSIS. There was no need for the publication or filing of these resolutions with the UP Law
Center. When it does not affect the general public, publication is no longer required.

Conte v. COA

The rule-making power of a public administrative body is a delegated legislative power, which it may not use
either to abridge the authority given it by the Congress or the Constitution or to enlarge its power beyond the
scope intended. Constitutional and statutory provisions control with respect to what rules and regulations may
be promulgated by such a body, as well as with respect to what fields are subject to regulation by it. It may not
make rules and regulations which are inconsistent with the provisions of the Constitution or a statute,
particularly the statute it is administering or which created it, or which are in derogation of, or defeat, the
purpose of a statute.

People v. Que Po Lay

Circulars and regulations especially like Circular No. 20 of the Central Bank which prescribes a penalty for its
violation should be published before becoming effective. Before the public is bound by its contents, especially
its penal provisions, a law, regulation or circular must first be published and the people officially and specifically
informed of said contents and its penalties.

Dagan v. Phil. Racing Commission (Philracom)

The validity of an administrative issuance, such as the assailed guidelines, hinges on compliance with the
following requisites:

1. Its promulgation must be authorized by the legislature.

2. It must be promulgated in accordance within the scope of the authority given by the legislature.
3. It must be within the scope of the authority given by the legislature.
4. It must be reasonable.

All the prescribed requisites are met as regards to the questioned issuances.

Victoria’s Milling Company, Inc vs. Social Security Commission

There can be no doubt that there is a distinction between an administrative rule or regulation and an
administrative interpretation of a law whose enforcement is entrusted to an administrative body. When an
administrative agency promulgates rules and regulations, it "makes" a new law with the force and effect of a
valid law, while when it renders an opinion or gives a statement of policy, it merely interprets a pre-existing law.
Rules and regulations when promulgated in pursuance of the procedure or authority conferred upon the
administrative agency by law, partake of the nature of a statute, and compliance therewith may be enforced by
a penal sanction provided therein. The details and the manner of carrying out the law are often times left to the
administrative agency entrusted with its enforcement. In this sense, it has been said that rules and regulations
are the product of a delegated power to create new or additional legal provisions that have the effect of law.
Therefore, Circular No. 22 purports merely to advise employers-members of the System of what, in the light of
the amendment of the law, they should include in determining the monthly compensation of their employees
upon which the social security contributions should be based, and that such circular did not require presidential
approval and publication in the Official Gazette for its effectivity. The Resolution appealed from is hereby
affirmed, with costs against appellant. So ordered.

Manuel vs. General Auditing Office

Rule over interpretation

(1) Administramtive rule binding on courts when valid.

— "The rule in question cannot supplement the plain and explicit statutory command. A rule is binding on the
courts as long as the procedure fixed for its promulgation is followed and its scope is within the statutory power
granted by the legislature, even if the courts are not in agreement with the policy stated therein or its innate
wisdom x x x."

(2) Administrative interpretation merely advisory on courts. — "On the other hand, administrative
interpretation of the law, is at best merely advisory, for it is the courts that finally determine what the law means
x x x. It cannot be otherwise as the Constitution limits the authority of the President, in whom all executive
power resides, to take care that the laws be faithfully executed.

No lesser administrative executive office or agency can, contrary to the express language of the Constitution,
assert for itself a more extensive prerogative. Necessarily, it is bound to observe the constitutional mandate.
There must be strict compliance with the legislative enactment. Its terms must be followed."

Lupangco vs. CA

The questioned resolution’s purpose is "to preserve the integrity and purity of the licensure examinations." The
unreasonableness is more obvious in that one who is caught committing the prohibited acts even without any
ill motives will be barred from taking future examinations conducted by the respondent PRC. Furthermore, it is
inconceivable how the Commission can manage to have a watchful eye on each and every examinee during the
three days before the examination period. To be valid, such rules and regulations must be reasonable and fairly
adapted to the end in view. If shown to bear no reasonable relation to the purposes for which they are
authorized to be issued, then they must be held to be invalid. Hence, PRC resolution is unconstitutional for being
unreasonable.
 CASES ON ADJUDICATORY POWERS

Eastern Shipping Lines, Inc. v. POEA

Appeals; Non-exhaustion of administrative remedies, proper; General rule that decisions of the POEA should
first be appealed to the NLRC; Case at bar comes under one of the exceptions, as the questions raised are
questions of law; Absence of objection by private respondent to petitioner’s direct resort to the Supreme Court.-
Ordinarily, the decisions of the POEA should first be appealed to the National Labor Relations Commission, on
the theory inter alia that the agency should be given an opportunity to correct the errors, if any, of its
subordinates. This case comes under one of the exceptions, however, as the questions the petitioner is raising
are essentially questions of law. Moreover, the private respondent herself has not objected to the petitioner’s
direct resort to this Court, observing that the usual procedure would delay the disposition of the case to her
prejudice.

Smart and PILTEL v. NTC

Jurisdiction: NTC vs. RTC

Administrative agencies possess quasi-legislative or rule-making powers and quasi-judicial or administrative
adjudicatory powers. Quasi-legislative or rule-making power is the power to make rules and regulations which
results in delegated legislation that is within the confines of the granting statute and the doctrine of non-
delegability and separability of powers.

The doctrine of primary jurisdiction applies only where the administrative agency exercises its quasi-judicial or
adjudicatory function. Thus, in cases involving specialized disputes, the practice has been to refer the same to
an administrative agency of special competence pursuant to the doctrine of primary jurisdiction. The courts will
not determine a controversy involving a question which is within the jurisdiction of the administrative tribunal
prior to the resolution of that question by the administrative tribunal, where the question demands the exercise
of sound administrative discretion requiring the special knowledge, experience and services of the
administrative tribunal to determine technical and intricate matters of fact, and a uniformity of ruling is essential
to comply with the premises of the regulatory statute administered.

Hence, the Regional Trial Court has jurisdiction to hear and decide Civil Case No. Q-00-42221. The Court of
Appeals erred in setting aside the orders of the trial court and in dismissing the case.

Mun. Council of Lemery, Batangas v. Provincial Board of Batangas

Whether the power exercised by the provincial board in approving or disapproving municipal resolutions is
quasi-judicial in nature

Yes, the power exercised by the provincial board in approving or disapproving a municipal resolution or
ordinances is in the nature of a quasi-judicial function.

This court interpreted section 2233 of the Administrative Code just quoted, in the case of Gabriel vs. Provincial
Board of Pampanga (50 Phil., 686), cited in Cariño vs. Jamoralne (p. 188, ante), as follows:

"The only ground upon which a provincial board may declare any municipal resolution, ordinance, or order
invalid is when such resolution, ordinance, or order is "beyond the powers conferred upon the council or
president making the same" (Administrative Code, sec. 2233). Absolutely no other ground is recognized by the
law. A strictly legal question is before the provincial board in its consideration of any municipal resolution,
ordinance, or order. The provincial disapproval of any resolution, ordinance, or order must be premised
specifically upon the fact that such resolution, ordinance, or order is outside the scope of the legal powers
conferred by law."

In vesting provincial boards with power to annul resolutions, and ordinances, passed by municipal councils in
excess of their powers, the law granted such provincial boards quasi-judicial powers, for the determination of
whether an act is legal or not, is an essentially judicial function.
It follows from the foregoing that the function exercised by the provincial board of Batangas in disapproving
resolution No. 18, series of 1931, of the municipal council of Lemery, through resolution No. 289, is a quasi-
judicial function.

CSC v. Dacoycoy

An administrative agency has standing to appeal the Civil Service Commission's repeal or modification of its
original decision. In such instances, it is included in the concept of a "party adversely affected" by a decision of
the Civil Service Commission granted the statutory right to appeal

PNB v. Garcia

Appeals; Parties; The interpretation of the phrase “party adversely affected” in Sec. 39 of PD 807 to refer solely
to the public officer or employee who was administratively disciplined has been overturned in Civil Service
Commission v. Dacoycoy, 306 SCRA 425 (1999).-

Citing Mendez v. Civil Service Commission, the CA construed the phrase "party adversely affected" in the above-
quoted provision to refer solely to the public officer or employee who was administratively disciplined. Hence,
an appeal may be availed of only in a case where the respondent is found guilty. However, this interpretation
has been overturned in Civil Service Commission v. Dacoycoy. Speaking through Justice Bernardo P. Pardo, the
Court said that “we now expressly abandon and overrule extant jurisprudence that the phrase ‘party adversely
affected by the decision’ refers to the government employee against whom the administrative case is filed for
the purpose of disciplinary action which may take the form of suspension, demotion in rank or salary, transfer,
removal or dismissal from office x x x.

Mathay v. CA

Every action must be prosecuted or defended in the name of the real party in interest; Real party in interest and
interest defined; In the case at bar, it is evident that Jovito C. Labajo, not the Civil Service Commission, is the
real party in interest.-

Basic is the rule that “every action must be prosecuted or defended in the name of the real party in interest.” A
real party in interest is the party who stands to be benefited or injured by the judgment in the suit, or the party
entitled to the avails of the suit. In Ralla vs. Ralla we defined interest as “material interest, an interest in issue
and to be affected by the decree, as distinguished from mere interest in the question involved, or mere
incidental interest.” As a general rule, one having no right or interest to protect cannot invoke the jurisdiction
of the court as a party-plaintiff in an action. In the case at bar, it is evident that Jovito C. Labajo, not the Civil
Service Commission, is the real party in interest. It is Jovito C. Labajo who will be benefited or injured by his
reinstatement or non-reinstatement.

Court rules that the Civil Service Commission has no legal standing to prosecute G.R. No. 126354.-
We fail to see how the present petition, involving as it does the reinstatement or non-reinstatement of one
obviously reluctant to litigate, can impair the effectiveness of government. Accordingly, the ruling in Dacoycoy
does not apply. To be sure, when the resolutions of the Civil Service Commission were brought before the Court
of Appeals, the Civil Service Commission was included only as a nominal party. As a quasi-judicial body, the Civil
Service Commission can be likened to a judge who should “detach himself from cases where his decision is
appealed to a higher court for review.” In instituting G.R. No. 126354, the Civil Service Commission dangerously
departed from its role as adjudicator and became an advocate. Its mandated function is to “hear and decide
administrative cases instituted by or brought before it directly or on appeal, including contested appointments
and to review decisions and actions of its offices and agen-cies,” not to litigate. Therefore, we rule that the Civil
Ser-vice Commission has no legal standing to prosecute G.R. No. 126354.

National Appellate Board of National Police Commission v. Mamamuag

The government party that can appeal is not the disciplining authority or tribunal which previously heard the
case and imposed the penalty of demotion or dismissal from the service—it must be one that is prosecuting the
administrative case against the respondent.-
RA 6975 itself does not authorize a private complainant to appeal a decision of the disciplining authority.
Sections 43 and 45 of RA 6975 authorize “either party” to appeal in the instances that the law allows appeal.
One party is the PNP member-respondent when the disciplining authority imposes the penalty of demotion or
dismissal from the service. The other party is the government when the disciplining authority imposes the
penalty of demotion but the government believes that dismissal from the service is the proper penalty. However,
the government party that can appeal is not the disciplining authority or tribunal which previously heard the
case and imposed the penalty of demotion or dismissal from the service. The government party appealing must
be one that is prosecuting the administrative case against the respondent. Otherwise, an anomalous situation
will result where the disciplining authority or tribunal hearing the case, instead of being impartial and detached,
becomes an active participant in prosecuting the respondent.

Heirs of Nicolas Jugalbot v. CA

For DARAB to have jurisdiction over a case there must exist a tenancy relationship between the parties. In order
for a tenancy agreement to take hold over a dispute, it would be essential to establish all the indispensable
elements of a landlord-tenant relationship. In the case at bar, petitioners are not de jure tenants of Virginia A.
Roa, hence, the DARAB has no jurisdiction over this case. The DARAB not only committed a serious error in
judgment, which the Court of Appeals properly corrected, but the former likewise committed a palpable error
in jurisdiction which is contrary to law and jurisprudence. We affirm the appellate court decision and likewise
hold that the DARAB gravely abused its discretion amounting to lack of jurisdiction on the grounds that the
subject matter of the present action is residential, and not agricultural, land, and that all the essential requisites
of a tenancy relationship were sorely lacking in the case at bar.

Heirs of Julian dela Cruz v. Heirs of Albert Cruz

The Court agrees with the petitioners contention that, under Section 2(f), Rule II of the DARAB Rules of
Procedure, the DARAB has jurisdiction over cases involving the issuance, correction and cancellation of CLOAs
which were registered with the LRA. However, for the DARAB to have jurisdiction in such cases, they must relate
to an agrarian dispute between landowner and tenants to whom CLOAs have been issued by the DAR Secretary.
The cases involving the issuance, correction and cancellation of the CLOAs by the DAR in the administrative
implementation of agrarian reform laws, rules and regulations to parties who are not agricultural tenants or
lessees are within the jurisdiction of the DAR and not of the DARAB.

In fine then, the petitioners should have filed their petition against Alberto Cruz with the DAR Secretary instead
of the DARAB. For its part, the DARAB should have dismissed the petition for lack of jurisdiction; or, at the very
least, transferred the petition to the DAR Secretary for resolution on its merits. In case the DAR Secretary denies
their petition, the petitioners may appeal to the Office of the President, and in case of an adverse ruling, a
petition for review with the CA under Rule 43 of the 1997 Rules of Civil Procedure.

Ang Tibay v. CIR

The fact, however, that the Court of Industrial Relations may be said to be free from the rigidity of certain
procedural requirements does not mean that it can, in justifiable cases before it, entirely ignore or disregard the
fundamental and essential requirements of due process in trials and investigations of an administrative
character. There are primary rights which must be respected even in proceedings of this character:

(1) The first of these rights is the right to a hearing, which includes the right of the party interested or affected
to present his own case and submit evidence in support thereof. In the language of Chief Hughes, in Morgan v.
U.S., 304 U.S. 1, 58 S. Ct. 773, 999, 82 Law. ed. 1129, "the liberty and property of the citizen shall be protected
by the rudimentary requirements of fair play.

(2) Not only must the party be given an opportunity to present his case and to adduce evidence tending to
establish the rights which he asserts but the tribunal must consider the evidence presented. (Chief Justice
Hughes in Morgan v. U.S. 298 U.S. 468, 56 S. Ct. 906, 80 law. ed. 1288.) In the language of this court in Edwards
vs. McCoy, 22 Phil., 598, "the right to adduce evidence, without the corresponding duty on the part of the board
to consider it, is vain. Such right is conspicuously futile if the person or persons to whom the evidence is
presented can thrust it aside without notice or consideration."
(3) "While the duty to deliberate does not impose the obligation to decide right, it does imply a necessity which
cannot be disregarded, namely, that of having something to support it is a nullity, a place when directly
attached." (Edwards vs. McCoy, supra.) This principle emanates from the more fundamental is contrary to the
vesting of unlimited power anywhere. Law is both a grant and a limitation upon power.

(4) Not only must there be some evidence to support a finding or conclusion (City of Manila vs. Agustin, G.R. No.
45844, promulgated November 29, 1937, XXXVI O. G. 1335), but the evidence must be "substantial."
(Washington, Virginia and Maryland Coach Co. v. national labor Relations Board, 301 U.S. 142, 147, 57 S. Ct. 648,
650, 81 Law. ed. 965.) It means such relevant evidence as a reasonable mind accept as adequate to support a
conclusion." (Appalachian Electric Power v. National Labor Relations Board, 4 Cir., 93 F. 2d 985, 989; National
Labor Relations Board v. Thompson Products, 6 Cir., 97 F. 2d 13, 15; Ballston-Stillwater Knitting Co. v. National
Labor Relations Board, 2 Cir., 98 F. 2d 758, 760.) . . . The statute provides that "the rules of evidence prevailing
in courts of law and equity shall not be controlling.' The obvious purpose of this and similar provisions is to free
administrative boards from the compulsion of technical rules so that the mere admission of matter which would
be deemed incompetent inn judicial proceedings would not invalidate the administrative order. (Interstate
Commerce Commission v. Baird, 194 U.S. 25, 44, 24 S. Ct. 563, 568, 48 Law. ed. 860; Interstate Commerce
Commission v. Louisville and Nashville R. Co., 227 U.S. 88, 93 33 S. Ct. 185, 187, 57 Law. ed. 431; United States
v. Abilene and Southern Ry. Co. S. Ct. 220, 225, 74 Law. ed. 624.) But this assurance of a desirable flexibility in
administrative procedure does not go far as to justify orders without a basis in evidence having rational
probative force. Mere uncorroborated hearsay or rumor does not constitute substantial evidence. (Consolidated
Edison Co. v. National Labor Relations Board, 59 S. Ct. 206, 83 Law. ed. No. 4, Adv. Op., p. 131.)"

(5) The decision must be rendered on the evidence presented at the hearing, or at least contained in the record
and disclosed to the parties affected. (Interstate Commence Commission vs. L. & N. R. Co., 227 U.S. 88, 33 S. Ct.
185, 57 Law. ed. 431.) Only by confining the administrative tribunal to the evidence disclosed to the parties, can
the latter be protected in their right to know and meet the case against them. It should not, however, detract
from their duty actively to see that the law is enforced, and for that purpose, to use the authorized legal methods
of securing evidence and informing itself of facts material and relevant to the controversy. Boards of inquiry
may be appointed for the purpose of investigating and determining the facts in any given case, but their report
and decision are only advisory. (Section 9, Commonwealth Act No. 103.) The Court of Industrial Relations may
refer any industrial or agricultural dispute or any matter under its consideration or advisement to a local board
of inquiry, a provincial fiscal. a justice of the peace or any public official in any part of the Philippines for
investigation, report and recommendation, and may delegate to such board or public official such powers and
functions as the said Court of Industrial Relations may deem necessary, but such delegation shall not affect the
exercise of the Court itself of any of its powers. (Section 10, ibid.)

(6) The Court of Industrial Relations or any of its judges, therefore, must act on its or his own independent
consideration of the law and facts of the controversy, and not simply accept the views of a subordinate in
arriving at a decision. It may be that the volume of work is such that it is literally Relations personally to decide
all controversies coming before them. In the United States the difficulty is solved with the enactment of
statutory authority authorizing examiners or other subordinates to render final decision, with the right to appeal
to board or commission, but in our case there is no such statutory authority.

(7) The Court of Industrial Relations should, in all controversial questions, render its decision in such a manner
that the parties to the proceeding can know the various issues involved, and the reasons for the decision
rendered. The performance of this duty is inseparable from the authority conferred upon it.

In the right of the foregoing fundamental principles, it is sufficient to observe here that, except as to the alleged
agreement between the Ang Tibay and the National Worker's Brotherhood (appendix A), the record is barren
and does not satisfy the thirst for a factual basis upon which to predicate, in a national way, a conclusion of law.

CARDINAL PRIMARY RIGHTS.-

There are cardinal primary rights which must be respected even in proceedings ofthis character. The first of
these rights is the right to a hearing, which includes the right of the party interested or affected to present his
own case and submit evidence in support thereof. Not only must the party be given an opportunity to present
his case and to adduce evidence tending to establish the rights which he asserts but the tribunal must consider
the evidence presented. While the duty to deliberate does not impose the obligation to decide right, it does
imply a necessity which cannot be disregarded, namely, that of having something to support its decision. Not
only must there be some evidence to support a finding or conclusion, but the evidence must be substantial. The
decision must be rendered on the evidence presented at the hearing, or at least contained in the record and
disclosed to the parties affected. The Court of Industrial Relations or any of its judges, therefore, must act on its
or his own independent consideration of the law and facts of the controversy, and not simply accept the views
of a subordinate in arriving at a decision. The Court of Industrial Relations should, in all controvercial questions,
render its decision in such a manner that the parties to the proceeding can know the various issues involved,
and the reasons for the decisions rendered. The performance of this duty is inseparable from the authority
conferred upon it.

Light Rail Transit Authority v. Aurora Salvaña

The parties may appeal in administrative cases involving members of the civil service. The present rule is that a
government party is a “party adversely affected” for purposes of appeal provided that the government party
with a right to appeal must be the office or agency prosecuting the case. The grant of the right to appeal in
administrative cases is not new. In Republic Act No. 2260 or the Civil Service Law of 1959, appeals “by the
respondent” were allowed on “the decision of the Commissioner of Civil Service rendered in an administrative
case involving discipline of subordinate officers and employees.” Thus, LRTA had standing to appeal the
modification by the Civil Service Commission of its decision.