Government of the Philippine Islands vs Springer (1).docx

Government of the Philippine Islands vs Springer Facts: On Nov. 9, 1926, the Governor- General promulgated Executive Order No. 37 wherein it declared that the provisions of the statutes passed by the Legislature which was about the creating of 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 the stocks, are null and void. It was announced that on account of the invalidity of some portions of the Acts which were about the voting committee, the Governor-General would exercise exclusively the duties and powers of the voting committee or board. On Dec. 6, 1926, a special meeting of the stockholders of the Philippine Mining Corporation was held. The Governor –General, through his representative, declared that he has the sole power to vote the stock of the Government and he also objected the asserted powers of the Senate President and the Speaker of the House. The House Speaker and the Senate President voted in favor of the defendants Milton Springer, Dalmacio Costas and Anselmo Hilario who were not favored by the Governor-General. After the stockholder’s meeting the chairman delacred the defendants as directors of the National Coal Company . A quo warranto was brought in the name of the Government of the Philippine Islands against the three defendants who were elected to their positions by the House Speaker and Senate President. The plaintiff questions the validity of Act. Nos. 2705 and 2882 which created the voting committee. Issue: Whether or not the Senate President together with the House Speaker can elect directors of the National Coal Company. Held: No, only the Governor-General has the power to appoint members or directors of the National Coal Company. The court held that that under the system of government of delegated powers, under which delegation legislative power vests in the Philippine Legislature and executive power vests in the Governor-General, and under which delegation a general power of appointment resides in the GovernorGeneral and a specified power of appointment resides in the Philippine Legislature, the latter cannot directly or indirectly perform functions of an executive nature through the designation of its presiding officers as majority members of a body which has executive functions.