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PNB Reorganization Validity Case

Petitioner Conchita Romualdez-Yap was a senior vice president at the Philippine National Bank (PNB) until she was separated from her position due to a reorganization of PNB under Executive Order 80. She argued the reorganization was done in bad faith and challenged the one-year prescriptive period for challenging her separation. The court held that the reorganization of PNB, a government-owned corporation providing non-essential banking services, was valid so long as it was done in good faith, which it found to be the case.

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Jonimar Coloma Quero
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71 views1 page

PNB Reorganization Validity Case

Petitioner Conchita Romualdez-Yap was a senior vice president at the Philippine National Bank (PNB) until she was separated from her position due to a reorganization of PNB under Executive Order 80. She argued the reorganization was done in bad faith and challenged the one-year prescriptive period for challenging her separation. The court held that the reorganization of PNB, a government-owned corporation providing non-essential banking services, was valid so long as it was done in good faith, which it found to be the case.

Uploaded by

Jonimar Coloma Quero
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Romualdez-Yap v.

CSC
FACTS: 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.
ISSUE: Is the reorganization of PNB, a government-owned or controlled corporation performing
ministrant functions, valid?
HELD: 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.

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