Romualdez-Yap v. CSC
Romualdez-Yap v. Civil Service Commission
225 SCRA 285
Petitioner Conchita Romualdez-Yap started working with the Philippine National Bank (PNB) on September 20, 1972. After several promotions, she was appointed in 1983 as a Senior Vice President assigned to the Fund Transfer Department. The case at bar is a special civil action for certiorari assailing Res. No. 92-201 of the respondent which upheld the petitioner’s separation from PNB in light of EO 80 or the Revised Charter of PNB. Petitioner contends that there is an existence of bad faith in its reorganization and that there is an erroneous application of the one year prescriptive period for quo warranto proceedings in her case.
Is the reorganization of PNB, a government-owned or controlled corporation performing ministrant functions, valid?
Ministrant functions are those undertaken by way of advancing the general interests of society and are merely optional. Commercial or universal banking is, ideally, not a governmental but a private sector endeavor, an optional function of the government. There are functions of the government which it may exercise to promote merely the welfare, progress, and prosperity of the people. Thus, reorganization of such corporations like PNB is valid so long as they are done in good faith as prescribed in the Dario v. Mison doctrine. Accordingly, the reorganization of PNB is found to be done in good faith by the Court.