This case has been cited 1 times or more.
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2007-02-13 |
SANDOVAL-GUTIERREZ, J. |
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| This case is a typical example of the practice of outgoing local chief executives to issue "midnight" appointments, especially after their successors have been proclaimed. It does not only cause animosities between the outgoing and the incoming officials, but also affects efficiency in local governance. Those appointed tend to devote their time and energy in defending their appointments instead of attending to their functions. However, not all "midnight" appointments are invalid.[3] Each appointment must be judged on the basis of the nature, character, and merits of the individual appointment and the circumstances surrounding the same.[4] It is only when the appointments were made en masse by the outgoing administration and shown to have been made through hurried maneuvers and under circumstances departing from good faith, morality, and propriety that this Court has struck down "midnight" appointments.[5] | |||||