Springer vs Govt of the Philippine Islands - Digest

Springer vs. Government of the Philippine Islands Argued April 10, 1928 Decided May 14, 1928 (scope and limit of legislative power, appointing power of the executive) FACTS - The National Coal Company (NCC) was created by Act 2705 (approved March 10, 1917) and subsequently amended by Act 2882 (March 5, 1919) - Act 2882 “The voting power of all such stocks owned by the Gov’t of the Philippines shall be vested exclusively in a committee, consisting of the Gov. Gen, the Pres. of the Senate, and the Speaker of the House of Representatives.” - The National Bank was created by Act 2612 (approved February 4, 1916) and subsequently amended by Act 2747 (February 20, 1918) and Act 1983 (January 30, 1921) - Original act: voting power vested exclusively on the Gov. Gen. - Amended acts: voting power vested in a board (Board of Control) composed of the Gov. Gen., Senate President, and Speaker of the House of Representatives - Same voting power in four other nationally organized / controlled stock corporations - The petitioners were elected directors of the NCC by a vote of the gov’t-owned shares cast by the Senate President and the Speaker of the House - The Governor General challenged the validity of the legislated amendments and did not participate in the elections ISSUE - Whether or not the amendments introduced by the legislated acts are unconstitutional HELD - Yes. The court sustained the contention of the Government that “the election of the directors and managing agents by a vote of the government-owned stock was an executive function entrusted by the Organic Act to the Gov. Gen, and that the acts of the Legislature, divesting him of the that power and vesting it, the majority of which in each instance consisted of officers and members of the Legislature, were invalid as being in conflict with the Organic Act.” - The court entered judgments of ouster against the petitioners NOTES - Sec. 8 of the Organic Act “That general legislative power, except as otherwise herein provided, is hereby granted to the Philippine Legislature, authorized by this Act’” - Sec. 21 “That the supreme executive power shall be vested in an executive officer… ‘The Governor General of the Phil. Islands’.” “…general supervision and control of all of the departments and bureaus of the government…” - Not having the power of appointment, unless expressly granted or incidental to its powers, the legislature cannot engraft executive duties upon a legislative office, since that would to usurp the power of appointment by indirection