Philippine Supreme Court Jurisprudence

On February 14, 2012, this Court En Banc approved Resolution No. 12-17 of the Philippine Judicial Academy (PHILJA) Board of Trustees, which had recommended a two-year membership term for the PHILJA Corps of Professors. The term began on April 12, 2012, without prejudice to subsequent reappointment.¹

Likewise, upon the PHILJA Board of Trustees' recommendation, this Court En Banc approved the appointment renewals of Justice Marina L. Buzon (Justice Buzon) as PHILJA's Executive Secretary and Justice Delilah Vidallon-Magtolis (Justice Vidallon-Magtolis) as head of PHILJA's Academic Affairs Office, both for two (2) years beginning June 1, 2012.²

Before the Corps of Professors' membership term expired on April 11, 2014, the PHILJA Board of Trustees recommended that it be renewed for another two (2) years beginning April 12, 2014. It was approved by this Court En Banc in A.M. No. 14-02-0l-SC-PHILJA.³

Similarly, when Justices Buzon's and Vidallon-Magtolis' terms of appointment were about to expire, the PHILJA Board of Trustees recommended that these be renewed for another two (2) years beginning June 1, 2014. This Court En Banc approved their term renewals in A.M. No. 14-02-02-SC-PHILJA.⁴ Their terms would further be renewed in 2014, 2016, and 2018.⁵

The current appointments of Justices Buzon and Vidallon-Magtolis would have expired on May 31, 2020.⁶ However, in a November 19, 2019 Resolution, the PHILJA Board of Trustees recommended that they be renewed for another two (2) years beginning June 1, 2020.⁷ PHILJA Chancellor Adolfo S. Azcuna later forwarded the recommendation to this Court En Banc for approval.⁸

Meanwhile, also on November 19, 2019, a certain Honesto Cruz (Cruz) sent a letter to this Court, raising concerns on the appointment renewals of Justice Buzon and Justice Vidallon-Magtolis given their ages and physical limitations. Cruz suggested appointing younger, more qualified, and more experienced professionals to introduce timely innovations to PHILJA.⁹

Created under Republic Act No. 8557, PHILJA is "a separate component unit of the Supreme Court"¹⁰ that provides "continuing good education and training"¹¹ to members of the Judiciary and its prospective applicants.¹²

It is tasked to "serve as a training school for justices, judges, court personnel, lawyers[,] and aspirants to judicial posts."¹³ It is mandated to "provide and implement a curriculum for judicial education, and ... conduct seminars, workshops[,] and other training programs designed to upgrade their legal knowledge, moral fitness, probity, efficiency, and capability."¹⁴

To effectively carry out PHILJA's mandate, the Corps of Professorial Lecturers, which makes up PHILJA's entire instructional force, is selected by the PHILJA Board of Trustees. The Board comes up with a list of lecturers, which will then be submitted to this Court for approval and formal appointment for two (2) years.¹⁵

In A.M. No. 01-1-04-SC-PHILJA, this Court elaborated on the organizational structure and functions of PHILJA officials. It created the Academic Council, whose task is to consider and approve PHILJA's programs, activities, and courses.¹⁶ This body is composed of the Department Chairs, heads of PHILJA's subject areas who are "recognized authorities in the subject areas to which they are appointed."¹⁷

To ensure that PHILJA efficiently and effectively performs its mandate in the rapidly evolving legal landscape, it must maintain its vibrancy by diversifying the composition of its offices, including its Academic Council and Corps of Professors.

This Court will now discontinue its policy of reappointments without limitations. While the Court does not intend to circumvent the provisions under Republic Act No. 8557, it will take a harder look and more restrictive attitude towards a second reappointment of any person as Chancellor, Vice Chancellor or member of the Executive Committee. This resolution adjusts the composition of the committees and offices in the PHILJA with a view of infusing younger members into the organization to revitalize its operations.

PHILJA plays an important role in ensuring "an efficient and credible Judiciary."¹⁸ Introducing younger officials and professors to PHILJA will amplify its academic expertise and leadership. Nonetheless, aware of the wisdom carried by our seniors, this Court will also maintain a needed proportion between the young and old.

1. Acting on the Letter of PHILJA Chancellor Adolfo S. Azcuna, the appointments of Justice Marina L. Buzon as PHILJA's Executive Secretary and Justice Delilah Vidallon-Magtolis as head of PHILJA's Academic Affairs Office are approved for equity reasons but only until December 31, 2020;
   
   
2. Except for the Executive Committee composed of the Chancellor, Vice-Chancellor, and Executive Secretary, no retired justice or judge above 75 years old shall be appointed in managerial or supervisory positions. No term of a retired judge or justice may be renewed more than once;
   
   
3. Retired justices or judges shall comprise not more than 50% of PHILJA's Corps of Professors and not more than 25% of the Academic Council and Management Offices;
   
   
4. The PHILJA Board of Trustees is directed to review and revise the memberships of the Corps of Professors, Academic Council, and Management Offices to ensure compliance with the composition limit within next year, no later than December 31, 2021; and
   
   
5. Retired personnel may continue to be appointed as advisers or consultants but without any administrative, managerial, or supervisory functions. No consultant or adviser may sit to vote in any regulatory committee.
   

Endnotes:

¹Rollo (A.M. No. 14-02-01-SC-PHILJA), p. 4.

²Rollo (A.M. No. 14-02-02-SC-PHILJA), p. 4.

³Rollo (A.M. No. 14-02-01-SC-PHILJA), pp. 16-21.

⁴Rollo (A.M. No. 14-02-02-SC-PHILJA), p. 5.

⁵ Id. at 5, 9, and 14.

⁶ Id. at 17.

⁷ Id.

⁸ Id. at 16.

⁹Rollo (A.M. No. 14-02-01-SC-PHILJA), p. 29.

¹⁰ Republic Act No. 8557 (1998), sec. 2.

¹¹ Republic Act No. 8557 (1998), sec. 1.

¹² Republic Act No. 8557 (1998), secs. 1 and 2.

¹³ Republic Act No. 8557 (1998), sec. 3.

¹⁴ Republic Act No. 8557 (1998), sec. 3.

¹⁵ Republic Act No. 8557 (1998), sec. 7.

¹⁶ A.M. No. 01-1-04-SC-PHILJA (2004), sec. 2.

¹⁷ A.M. No. 01-1-04-SC-PHILJA (2004), sec. 2.1.

¹⁸ Republic Act No. 8557 (1998), sec. 1.