Ampaso Case

A.M. No. 91-10-160 (May 15, 1996)

Samanodin L. Ampaso's Jurisconsult appointment was annulled for age, despite his birthdate claims.

Facts:

Samanodin L. Ampaso was appointed as Jurisconsult in Islamic Law on March 26, 1991, by then President Corazon C. Aquino, and took his oath of office on April 10, 1991. This position was established under Section 164, paragraph 2 of Presidential Decree No. 1083, known as the Code of Muslim Personal Laws of the Philippines. Following his appointment, Ampaso requested the Supreme Court to upgrade his position to Salary Grade 31, which is equivalent to that of an Associate Justice of the Supreme Court, asserting that he was the highest Muslim Judicial Officer in the Philippines under the same decree. He also proposed the creation of 209 staff positions for the Office of the Jurisconsult.

Under P.D. 1083, the Jurisconsult is responsible for rendering legal opinions on matters related to Muslim law and assists the Qadi (Judge) by providing fatwas (legal opinions). The opinions are advisory and not binding on the court or the parties involved.

However, an investigation by the Office of the Court Administrator revealed that Ampaso was born on January 2, 1952, which meant he was only 39 years old at the time of his appointment, failing to meet the age requirement of at least 40 years as stipulated in Article 165 of P.D. 1083. Consequently, on March 31, 1992, the Court required Ampaso to show cause why he should not be removed from office for not fulfilling the age requirement.

In his response, Ampaso claimed that his actual birthdate was January 2, 1948, and that the discrepancy in his age was due to an error made by his brother, who filled out his personal data forms. To support his assertion, he submitted various documents, including a passport and a late-registration birth certificate.

Legal Issues:

  1. Was Samanodin L. Ampaso's appointment as Jurisconsult valid given the age requirement stipulated in P.D. 1083?
  2. If the appointment was invalid, does this affect his request for an upgrade in salary?

Arguments:

  • Ampaso's Argument: Ampaso contended that the incorrect year of birth was an innocent mistake made by his brother, who filled out the forms. He argued that he had submitted sufficient documentation to prove his actual birthdate and that the misstatement was not made in bad faith.

  • Court's Argument: The Court found Ampaso's explanation to be implausible and unacceptable. It emphasized that as a person aspiring for a high office, it was his responsibility to ensure the accuracy of the information he provided. The Court noted that the documents submitted by Ampaso, including the late-registration birth certificate and affidavits, were insufficient to prove his actual date of birth and were considered hearsay and self-serving.

Court's Decision and Legal Reasoning:

The Court declared Ampaso's appointment as Jurisconsult null and void ab initio, meaning it was invalid from the outset. The Court reasoned that Ampaso's failure to meet the age requirement at the time of his appointment rendered his position legally invalid. The Court rejected his claims regarding the misstatement of his birthdate, stating that it was improbable for someone in his position to rely on another person to fill out such critical personal information. Furthermore, the Court found that the evidence presented by Ampaso did not adequately establish his actual date of birth.

Significant Legal Principles or Doctrines Established:

  1. Strict Compliance with Qualifications: The case underscores the importance of strict adherence to the qualifications set forth in laws governing appointments to public office. Failure to meet any of the stipulated requirements can result in the invalidation of the appointment.

  2. Responsibility for Personal Data: Individuals seeking public office must take personal responsibility for the accuracy of their personal data. Relying on others to provide such information is not a valid excuse for discrepancies.

  3. Validity of Appointments: The ruling reinforces the principle that appointments to public office must comply with all legal requirements from the outset; otherwise, they are considered void.