Manila Prince Prince Hotel v. GSIS GR 122156, 3 February 1997 F!"S# The Government Service Insurance System (GSIS), pursuant to the privatization program of the Philippine Government under Proclamation 50 dated !ecem"er #$%, decided to sell through pu"lic "idding "idding &0' to 5#' of the issued issued and outstanding outstanding shares of the anila otel (*)+ (*)+ In a close "idding "idding held on # Septem"er #$$5 only to "idders participated- anila Prince otel *orporation, a .ilipino corporation, hich offered to "uy 5#' of the * or #5,&00,000 shares at P/#+5 per share, and enong 1erhad, a alaysian firm, ith ITT2Sheraton ITT2Sheraton as its hotel operator, hich "id for the same num"er of shares at P//+00 per share, or P3+/3 more than the "id of petitioner+ Pending the declaration of enong 1erhard as the inning "idder4strategic partner and the eecution of the necessary contracts, the anila Prince otel matched the "id price of P//+00 per share tendered "y enong 1erhad in a letter to GSIS dated 3 Septem"er #$$5+ anila Prince otel sent a manager6s chec7 to the GSIS in a su"se8uent letter, "ut hich GSIS refused to accept+ 9n #: 9cto"er #$$5, perhaps apprehensive that GSIS has disregarded the tender of the matching "id and that the sale of 5#' of the * may "e hastened "y GSIS and consummated ith enong 1erhad, anila Prince otel came to the *ourt on prohi"ition and mandamus+ ISS$%# ;hether ;hether or not the provisions provisions of the *onstitut *onstitution, ion, particula particularly rly
oyed or protected, is self2eecuting+ Thus a constitutional provision is self2eecuting if the nature and etent of the right conferred and the lia"ility imposed are fied "y the constitution itself, so that they can "e determined "y an eamination and construction of its terms, and there is no language indicating that the su">ect is referred to the legislature for action+ In fine, Section #0, second paragraph, urisdiction, as in the third paragraph, then a fortiori, "y the same logic, the second paragraph can only "e selfeecuting as it does not "y its language re8uire any legislation in order to give preference to 8ualified .ilipinos in the grant of rights, privileges and concessions covering the national economy and patrimony+ < constitutional provision may "e self2eecuting in one part and non2self2eecuting in another+
I(bon) v*. +coa, GR 2-/19, 0ril /, 2-1 F!"S# This is a petition for declaratory >udgment+ These are 3 separate "ut related petitions of running candidates for delegates to the *onstitutional *onvention assailing the validity of < %#&3+ I**ue # ;hether or not (;9@) < #0&5/4eproductive ealth () Aa is unconstitutional for violating the ight to health @9+ Petitioners claim that the right to health is violated "y the Aa "ecause it re8uires the inclus inclusion ion of hormon hormonal al contra contracep ceptiv tives, es, intrau intrauter terine ine device devices, s, in>ect in>ecta"l a"les es and other other safe, safe, legal, legal, non2 non2 a"ortifacient and effective family planning products and supplies in the @ational !rug .ormulary and in the regular purchase of essential medicines and supplies of all national hospitals (Section $ of the Aa)+ They cite ris7s of getting diseases gained "y using e+g+ oral contraceptive pills+ Some petitioners do not 8uestion contraception and contraceptives per se+ ather, they pray that the status 8uo under < /:3$ and 5$3# "e maintained+ These las prohi"it the sale and distri"ution of contraceptives ithout the prescription of a duly2licensed physician+ The Aa does not intend intend to do aay ith < /:3$ /:3$ (#$%%)+ (#$%%)+ ;ith ;ith < /:3$ in place, the *ourt "elieves ade8uate safeguards eist to ensure that only safe contraceptives are made availa"le to the pu"lic+ In fulfilling its mandate under Sec+ #0 of the Aa, the !9 must 7eep in mind the provisions of < /:3$- the contraceptives it ill procure shall "e from a duly licensed drug store or pharmaceutical company and that the actual distri"ution of these contraceptive drugs and devices ill "e done folloing a prescription of a 8ualified medical practitioner+ The requirement of Section 9 of the RH Law is to be considered “mandatory” only after these devices and materials have been tested, evaluated and approved by the !"# $on%ress cannot determine that contraceptives are “safe, le%al, non&abortificient and effective”# Reprod Reproduct uctiv ive e Health Health Law' Law' The Repro Reproduc ducti tive ve Healt Health h (RH) (RH) Law drasti drastical cally ly affect affects s the consti constitut tution ional al provisions on the ri%ht to life and health, the freedom of o f reli%ion and e*pression and other constitutional ri%hts# +indful of all these and the fact that the issues of contraception and reproductive health have already caused deep division amon% a broad spectrum of society, the Supreme $ourt entertains no doubt that the petitions raise issues of transcendental importance warrantin% immediate court adudication#-.n view of the seriousness, novelty and wei%ht as precedents, not only to the public, but also to the bench and bar, the issues raised must be resolved for the %uidance of all# "fter all, the RH Law drastically affects the constitutional provisions on the ri%ht to life and health, the freedom of reli%ion and e*pression and other constitutional ri%hts# +indful of all these and the fact that the issues of contraception and reproductive health have already caused deep division amon% a broad spectrum of society, the $ourt entertains no doubt that the petitions raise issues of transcendental importance warrantin% immediate court adudication# +ore importantly, considerin% that it is the ri%ht to life of the mother and the unborn which is primarily at issue, the $ourt need not wait for a life to be ta/en away before ta/in% action# The $ourt cannot, and should not, e*ercise udicial restraint at this time when ri%hts enshrined in the $onstitution are bein% imperilled to be violated# To do so, when the life of either the mother or her child is at sta/e, would lead to irreparable consequences# 0hile the Supreme $ourt has opted not to ma/e any determination when life be%ins, it finds that the Reproductive Health (RH) Law itself clearly mandates that protection be afforded from the moment of fertili1ation#-The fertili1ation#-The clear and unequivocal intent o f the ramers of the 2934 $onstitution in protectin% the life of the unborn from conception was to prevent the Le%islature from enactin% a measure le%ali1in% abortion# .t was so clear that even the $ourt cannot interpret it otherwise# This intent of the ramers was captured in the record of the proceedin%s of the 2935 $onstitutional $ommission# $ommission# * * * " readin% of the RH Law would show that it is in line with this intent and actually proscribes abortion# 0hile the $ourt has opted not to ma/e any determination, at this sta%e, when life be%ins, it finds that the RH Law itself clearly mandates that protection b e afforded from the moment of fertili1ation# fertili1ation# "s pointed p ointed out by 6ustice $arpio, the RH Law is replete with provisions that embody the policy of the law to protect to the fertili1ed ovum and that it should be afforded safe travel to the uterus for implantation# +oreover, the RH Law reco%ni1es that abortion is a crime crime under "rticle "rticle 785 of the Revised enal $ode, which penali1es penali1es the destructio destruction n or e*pulsion of the fertili1ed ovum#
illavicencio v*. &uban Fact* 9ne hundred hundred and seventy seventy omen omen ere isolated isolated from society society,, and then at night, night, ithout ithout their consent and ithout any opportunity to consult ith friends or to defend their rights, ere forci"ly hustled on "oard steamers for transportation to regions un7non+ !espite the fee"le attempt to prove that the omen left voluntarily and gladly, that such as not the case is shon "y the mere fact that the presence of the police and the consta"ulary as deemed necessary and that these officers of the la chose the shades of night to cloa7 their secret and stealthy acts+ Indeed, this is a fact impossi"le to refute and practically admitted "y the respondents+ ISS$%# ;hether e are a government of las or a government of men+ R$&I'G# We are clearly a government of laws. Au7"an laws. Au7"an committed a grave a"use of discretion "y deporting the prostitutes to a ne domicile against their ill+ There is no la epressly authorizing his action+ 9n the contrary, there is a la punishing pu"lic officials, not epressly authorized "y la or regulation, ho compels any person to change his residence+ .urthermore, the prostitutes are still, as citizens of the Philippines, entitled to the same rights, as stipulated in the 1ill of ight ights, s, as every every other other citiz citizen+ en+ Their Their choice choice of profes professio sion n shoul should d not "e a cause cause for discrimina discrimination+ tion+ It may ma7e some, li7e Au7"an, 8uite uncomforta uncomforta"le "le "ut it does not authorize authorize anyone to compel said prostitutes to isolate themselves from the rest of the human race+ These omen have "een deprived of their li"erty "y "eing eiled to !avao ithout even "eing given the opportunity to collect their "elongings or, orse, ithout even consenting to "eing transported to indanao+ .or this, Au7"an et al must "e severely punished+ 0hen one is commanded to produce a certain person and does not do so, and does not offer a valid e*cuse, a court must, to vindicate its authority, adud%e the respondent to be %uilty of contempt, and must order him either imprisoned or fined# "n officer:s failure to produce the body of a person in obedience to a writ &of habeas corpus, when he has power to do so, is is contempt committed committed in the face face of the court# ;<=>R?+>?T ;<=>R?+>?T < TH> H.L..?> H.L..?> .SL"?!S' " ;<=>R?+>?T ;<=>R?+>?T < L"0S#-The L"0S#-The ;overnment ;overnment of the hilippine .slands is a# %overnment of laws# The court will assist in retainin% it as a %overnment of laws and not of men# ?o official, however hi%h, is above the law# el)ica v* +coa .actsPor7 1arrel refers to an appropriation appropriation of government government spending spending meant for localized localized pro>ects pro>ects and secured secured solely or primarily to "ring money to a representative6s district+ district+ unction dated
P!<. and CIAP from the years 300& to 30#&+ The use of eecutive6s lump sum, discretionary funds, including the proceeds f rom the malampaya funds and remittances from the P
Su"stantive Issue on the Presidential Por7 1arrel;o@ ;o@ the the 30#& 30#& P!<. P!<. arti articl cle e and and all all other other *ong *ongre ress ssio iona nall Por7 Por7 1arr 1arrel el Aas Aas simi simila larr ther theret eto o are are unconstitutional considering that they violate the principles of constitutional provisions on (non2delaga"ility of legislative poer) (chec7s and "alances)
*ourt6s uling@on2delaga"ility of Aegislative Poer The court court o"serv o"serves es that that the 30#& 30#& P!<. P!<. articl article e viola violates tes the princi principle ple of non2de non2delag laga"i a"ili lity ty since since said said legislators are effectively alloed to individually eercise the poer of appropriation+ That the poer to appropriat appropriate e must "e eercised eercised only through through legislati legislation on is clear from Section Section 3$(#)
n)ara v* %lectoral !o((i**ion Petitioner2 Eose udicial >udicial departmen departmentt is the only only constitut constitutional ional organ organ hich hich may determi determine ne the proper allocation of poers+ %+ S* determines determines the the scope, nature, nature, and etent etent the poers poers of government government and and hen the S* mediates mediates to allocate constitutional "oundaries, it does @9T assert any superiority over the legislative and e ecutive "ranch 1BT asserts the S9AF@ and S<*F! o"ligation assigned to it "y the *onsti+ to determine conflicting claims of authority "eteen and among "ranches the govt+ &+ F* shall prevail "ecause of .act @o+ 5+ !ecision- the F* can entertain the protest of nsua+
Guro Party &i*t v Puri*i(a Petitioner- <1oint congressional committee is valid and constitutional
H%&# #+ @o+ It is unconstitut unconstitutional ional++ It constitutes constitutes an encroachmen encroachmentt on the eecutive eecutive poer to implement implement las las nor undermines the constitutional separation of poers+ 3+ The The po poer of over oversi sigh ghtt em"r em"rac aces es all all acti activi viti ties es unde undert rta7 a7en en "y *ong *ongre ress ss to enha enhanc nce e its its understanding of and influence over the Implementation of legislation it has enacted+ *learly, oversi oversight ght concer concerns ns post2e post2enac nactme tment nt measur measures es undert underta7e a7en n "y *ongr *ongress ess-- (a) to monit monitor or "ureaucratic compliance ith program o">ectives, (") to determine hether agencies are properly administered, (c) to eliminate eecutive aste and dishonesty, (d) to prevent eecutive usurpation of legislative authority, and (d) to assess eecutive conformity ith the congressional perception of pu"lic interest+ &+ The poer poer of oversigh oversightt has "een held to "e intrin intrinsic sic in the grant grant of legislat legislative ive poer poer itself itself and integral to the chec7s and "alances inherent in a democratic system of government+ . !"% !"%G+RI G+RI%S %S +F !+'GR%S !+'GR%SSI+' SI+'& & +%RS +%RSIGH" IGH" F$'!" F$'!"I+'S I+'S #+ Scrutiny "ased primarily on *ongressK poer of appropriation and the "udget hearings conducted in con nection ithit, its poer to as7 heads of departments to appear "efore and "e heard "y either of its ouses on any matter pertaining to their departments and its poer of confirmation 3+ !on)re**ional !on)re**ional Inve*ti)ation Inve*ti)ation 2 investigat investigation ion and monitori monitoring ng of the implement implementation ation of las pursuant to the poer of *ongress to conduct in8uiries in aid of legislation+
&e)i*lative veto 2 veto 2 statutory provision re8uiring the President or an administrative agency to present the proposed implementing rules and regulations of a la to *ongress hich, "y itself or through a committee formed "y it, retains a HrightH or HpoerH to approve or disapprove such regulations "efore they ta7e effect+ urisdiction of these Tri"unals+ The Supreme *ourt under the #$: *onstitution, has "een given an epanded >urisdiction, so to spea7, to revie the decisions of the other "ranches and agencies of the government to determine hether or not they they have have acte acted d ith ithin in the the "oun "ounds ds of the the *ons *onsti titu tuti tion+ on+ (See urisdiction, not that it erred or has a different vie+ In the a"sence of a shoing that the FT has committed grave a"use of discretion amounting to lac7 of >urisdiction, there is no occasion for the *ourt to eercise its corrective poerN it ill not decide a matter hich "y its nature is for the FT alone to decide+ ( See arcos See arcos v+ anglapus, #:: S*< %% #$$J) It has no poer to loo7 into hat it thin7s is apparent error+ In the case at "ar, the *ourt finds no improvident use of poer, no denial of due process on the part of the FT hich ill necessitate the eercise of the poer of >udicial revie "y the Supreme *ourt+ +n !itien*i0
Fven assuming that the private respondent does n ot on any property in Samar, the Supreme *ourt in the case of !e !e los Reyes v + Solidum (%# Solidum (%# Phil+ $& #$&5J) held that it is not re8uired that a person should have a house in order to esta"lish his residence and domicile+ .t is enou%h that he should live in the municipality or in a rented house or in that of a friend or relative + (Fmp (Fmpha hasi sis s supp suppli lied ed)) To re8uire the private respondent to on property in order to "e eligi"le to run for *ongress ould "e tantamount to a property 8ualification+ The *onstitution only re8uires that the candidate meet the age, citize citizensh nship, ip, voting voting and resid residence ence re8uir re8uireme ements nts++ @oher @ohere e is it re8uir re8uired ed "y the *onsti *onstitut tution ion that that the candidate should also on property in order to "e 8ualified to run+ ( see a8uera see a8uera v+ 1orra, #33 Phil+ /#3 #$%5J) The *ourt cannot go into the collateral procedure of stripping respondent6s father of his citizenship after his death+
Petitioner# en)on Re*0on:ent# Senate lue Ribbon !o((ittee .acts#+ !efendants !efendants (Do7oy) (Do7oy) omualdez omualdez and Euliette Gomez omualdez omualdez,, acting "y themselves themselves and4or and4or in unlaful concert ith !efendants .erdinand F+ arcos and Imelda + arcos, and ta7ing undue advantage of their relationship, influence and connection ith the latter !efendant spouses, engaged in devices, schemes and strategems to un>ustly enrich themselves at the epense of Plaintiff Plaintiff and the .ilipino people+ 3+ Petitioner 1engzon and icardo Aopa ere su"poenad "y the *ommittee to appear "efore it and testify on Lhat they 7noM regarding the & % corporations "elonging to omualdez and properties ac8uired "y the latter+ &+ 1engzon and Aopa refused, averred that their testimony ould unduly pre>udice the defendants and against the *onstitutional right to due process+ /+ S* as in favor of the Petitioners Issue- Eusticea"le or Political Ouestion uling- Eusticea"le Ouestion+ ( < >usticia"le 8uestion is one that can "e decided "y courts li7e issues arising out of o"ligations and contracts, and violations of las, etc+ The courts have >urisdiction over these things, meaning they can hold a trial and issue >udgments+ ) #+ The allocation of constitutional "oundaries is a tas7 that this *ourt must perform under the *onstitution+ 3+ The >urisdiction to delimit constitutional "oundaries has "een given to this *ourt+ &+ Aastly, the the *ourt is thus of the considered vie that it has >urisdiction over the present controversy for the purpose of determining the scope and etent of the poer of the Senate 1lue i""on *ommittee to conduct in8uiries into private affairs in purported aid of legislation+ "a;a:a v*. n)ara, GR 11/295, May 2, 1997 F!"S# 9n
This is a petition assailing the constitutionality of the ;T9 agreement as it violates Sec #$,
R$&I'G# The Supreme *ourt ruled the esolution @o+ $: is not unconstitutional+ ;hile the constitution mandates a "ias in favor of .ilipino goods, services, la"or and enterprises, at the same time, it recognizes the need for "usiness echange ith the rest of the orld on the "ases of e8uality and reciprocity and limits protection of .ilipino interests only against foreign competition and trade practices that are unfair+ In other ords, the *onstitution did not intend to pursue a n isolationalist policy+ policy+ .urthermore, the constitutional policy of a Lself2 reliant and independent national economyM does not necessarily rule out the entry of foreign investments, goods and services+ It contemplates neither Leconomic seclusionM nor Lmendicancy in the international community+M The Senate, after deli"eration and voting, gave its consent to the ;T9
.acts#+ Sen+ iriam Santiago and Sen+ .rancisco Tatad Tatad instituted a petition for 8uo arranto see7ing the ouster of Sen+ Teofisto Teofisto Guingona as minority leader of the Senate and the declaration of Sen+ Tatad Tatad as the ightful minority leader+ 3+ usticia"le 8uestion is one that can "e decided "y courts li7e issues arising out of o"ligations and contracts, and violations of las, etc+ The courts have >urisdiction over these things, meaning they can hold a trial and issue >udgments+ ) 3+ *ourts have no poer to in8uire into the internal organization and "usiness of a house of *ongress ecept as the 8uestion affects the rights of third parties or a specific constitutional limitation limitation is involved+ &+ Indeed, these matters matters pertain to the internal government government of *ongress and are =itin =itin its eclusive >urisdiction+
Peo0le v acuycuy Fact*Fact*Private respondents ere charged ith violation of < /%:0 (agna *arta for Pu"lic School Teachers+ They also charged constitutionality of Sec+&3 (Q"e punished "y a fine of not less than P#00 nor more than P#000, or "y imprisonment, in the discretion of the court+) of said +< on grounds that it a+) imposes a cruel and unusual punishment, "+) constitutes an undue delegation of legislative poer+ Eudge !acuycuy ruled
that the said section is a matter of statutory construction and not an undue of delegation of legislative poer+ I**ue# ;4@ Sec+ % constitutes undue delegation of legislative poer and is valid+
Hel:# @9T Cudicial >udicial department department as a legislativ legislative e dep6t+ dep6t+ The eercise eercise of >udicial >udicial poer not an attempt attempt to use legislative poer or to prescri"e and create a la "ut is an instance of the admin+ of >ustice and the app+ of eisting las to the facts of particular cases+ Said section violates the rules on separation of poers and non2delega"ility of legislative poers !ion)bian v* +rbo* Fact* In #$%, #$%, +<+ +<+ 5/&5 5/&5 author authorize ized d the Presi Presiden dentt of the Phili Philippi ppines nes,, ith ith the help of *ommi *ommissi ssion on on eorga eorganiz nizati ation, on, to recogn recogniz ize e the differ different ent eecut eecutiv ive e depart departmen ments, ts, "ureau "ureaus, s, offic offices, es, agenci agencies, es, and instrumentalities of the government, including "an7ing or financial institutions and corporations oned or controlled "y it+ Pur0o*e =a* to 0ro(ote *i(0licity, econo(y an: e<i*tin) re)ion* and cannot "e construed as reor)aniin) them+ reor)aniin) them+ I**ue 8?' te 0o=er to (er)e a:(ini*trative re)ion* i* le)i*lative 40etitioner@* *tan: in caracter or e>ecutive a* te re*0on:ent* re*0on:ent* conten: R Peti Petiti tion oner erss- It undu unduly ly dele delega gate tes s poe poerr to the the Pres Presid iden entt to merg merge e regi region ons s thr through ough administrative determination or at any rate provides no standard for the eercise of the poer delegated R esp espon onde dent ntss- @o undue undue deleg delegat atio ion n "ut only only a gran grantt of poer poer to
Petitioners# Petitioners# R+M% R+M%+ + P. G%R+ G%R+!H !HI, I, " "$&+' $&+'G G 'G A A' 4 4 an: an: %'I %'IR+ R+'M 'M%' %'" "&I &IS" S" !+'S$M%RS '%"8+R, I'!. 4%!', espon esponden dentsts- %P %PR"M%'" R"M%'" +F %'%RGA %'%RGA 4+%, 4+%, %'%RGA %'%RGA R%G$& R%G$&"+ "+RA RA !+MMISSI !+MMISSI+' +' 4%R!, 4%R!, '" '"I+' I+'& & P+8% P+8%R R !+RP !+RP+R +R "I+' I+' 4'P! 4'P!, , P+8% P+8%R R S%!" S%!"+R +R SS%" SS%"S S ' &I &II& I&I" I"I% I%S S M'G%M% M'G%M%'" '" GR+$P GR+$P 4PS&M 4PS&M !or0., !or0., S"R"% S"R"%GI! GI! P+8%R P+8%R $"I&I"I% $"I&I"I%S S GR+$P GR+$P 4SP$G, 4SP$G, an: P'A P'A %&%!"RI! !+MP'A I'!. 4P%!+, 4P%!+ , .actsPetitoner Gerochi 8uestioned the constitutionality of the implementation of Bniversal charge in electric "ill and alleged that SF* &/ of FPI< la or Bniversal charge ta hich is to "e collected from all end2users and self2generating entities+ The poer to ta is strictly a legislative function thus, delegation of said poer to any admin agency li7e F* in unconstitutional+ ISSBF- ;hether or not there is undue delegation of poer to ta on the part of F* FA!- '+ FA!- '+++ #+ If generation generation of revenue revenue is the primary primary purpose purpose and regulation regulation is merely merely incidental incidental,, the imposition imposition is a taN "ut if regulation is the primary purpose, the fact that revenue is incidentally raised does not ma7e the imposition a ta+ In eacting the assailed Bniversal *harge through Sec+ &/ of the FPI<, the StateKs police poer, particularly its regulatory dimension, is invo7ed+ Such can "e deduce deduced d from from Sec+ Sec+ &/ hich hich enumer enumerate ates s the purpos purposes es for hich the Bniver Bniversal sal *harg *harge e is imposed and hich can "e amply discerned as regulatory in character+ The FPI< resonates resonates such regulatory purposes on Sec+3+ 3+ ects and purposes of the la and that the regulation "e not in contradiction to, "ut in conformity ith, the standards prescri"ed "y the la+ These re8uirements are denominated as the completeness test and the sufficient standard test+ &+ Bnder Bnder the first first test, the la must must "e comple complete te in all its terms terms and conditio conditions ns hen it leaves leaves the legislature such that hen it reaches the delegate, the only thing he ill have to do is to enforce it+ The second second test test mandat mandates es ade8ua ade8uate te guidel guideline ines s or limita limitati tions ons in the la to determ determin ine e the "oundaries of the delegateKs authority and prevent the delegation from running riot+ The *ourt finds that the FPI<, read and appreciated in its entirety, in relation to Sec+ &/ thereof, is complete in all its essential terms and conditions, and that it contains sufficient standards+ ustice H>ustice and e8uityNH Hpu"lic convenience and elfareNH Hsimplicity, economy and efficiencyNH Hstandardization and regulation of medical educationNH and Hfair and e8uita"le employment practices+H Provisions of the FPI< such as, among others, to ensure the total electrification of the country and the 8uality, relia"ility, relia"ility, security and afforda"ility of the supply of electric poer and atershed reha"ilitation and
management meet the re8uirements for valid delegation, as they provide the limitations on the F*s poer to formulate the I+ These are sufficient standards+
illena v* Secretary o< Interior 4octrine o< Bualiunc in>unctio tion n agains againstt the Sec+ Sec+ to restra restrain in him him and his his agents agents from from procee proceedin ding g ith ith the investigation+ ISS$%# ;hether or not the Secretary of Interior can suspend an AGB official under investigation+ H%&# es+ sThe Secretary of Interior has the poer to order investigation and to suspend ayor Cillena+ urisdiction+ This as interpreted in relation to Sectio Section n % of the same same *ode *ode hich hich grante granted d the said said !epart !epartmen mentt of eecut eecutiv ive e superv supervisi ision on over over administration of provinces, municipalities and other political su"divisions+ This supervision covers the poer to order investigation "ecause supervision Limplies authority to in8uire into facts and conditions in order to render poer real and effective+Moever, unli7e this poer to order investigation, the poer to suspend a mayor as not provided in any la+ There as no epress grant of authority to the Secretary of Interior to suspend a ayor+ @evertheless, Section 3# of the
