Constitutional Law I

Group 2

1JD-C - 2015
Atty. David Yap

Springer vs. Government of the Philippine Islands

G.R. No. L-26979
April 1, 1927
FACTS:
On November 9, 1926, the Government-General promulgated Executive Order No. 37.
Reference was made therein to opinions of the Judge Advocate General of the United States
Army and of the Acting Attorney-General of the United States wherein it was held that the
provisions of the statutes passed by the Philippine Legislature creating a voting committee or
board of control, and enumerating the duties and powers thereof with respect to certain
corporations in which the Philippine Government is the owner of stock, are nullities.
On December 6,1926 There was a meeting regarding the elections of offices of the National
Coal Commission.The Governor Generals representative was objecting about the validity of the
elections but the chair was recognizing the president of the senate and the speaker of the house
of representatives who were present majority members of the voting committee as the persons
lawfully entitled to represent and vote the Government stock.The President of the Senate and
the Speaker of the House of Representatives was in favor of Alberto Barretto,Milton E. Springer,
Dalmacio Costas, Anselmo Hilario, and Frank B. Ingersoll. The Governor-General through his
representative, alleging representation of the Government stock, cast his vote in favor of Alberto
Barreto, Romarico Agcaoili, Frank B. Ingersoll, H. L. Heath, and Salvador Lagdameo. The chair
declared the ballot cast by the President of the Senate and the Speaker of the House as
electing the names therein indicated, directors of the National Coal Company.On 1927,an action
of quo warranto brought in the name of the Government of the Philippine Islands against three
directors of the National Coal Company who were elected to their positions by the legislative
members of the committee created by Acts. Nos. 2705 and 2822.
ISSUE:
Whether or not the Senate President as well as the House Speaker can elect the Board
Members of National Coal Company. The doctrine of separation of powers should be
HELD:
No. Only the Governor General has the right to choose the board members of the National Coal
Company.The prohibition on the local Legislature, which has been thought of as referring to the
Resident Commissioners, is that "No Senator or Representative shall, during the time for which
he may have been elected, be eligible to any office the election to which is vested in the
Legislature, nor shall be appointed to any office of trust or profit which shall have been created
or the emoluments of which shall have been increased during such term." (Organic Act, sec.
18.).The legislative, judicial and executive parts of the government should realize their assigned
duties through the doctrine of separation of powers written in the Philippine Organic Law
(Constitution).