RUPERTO V TORRES

DOCTRINE:
Not every function wherein judgment and discretion are exercised is a judicial function.

The test of judicial function is not the exercise of judicial discretion, but the power and authority to
adjudicate upon the rights and obligations of the parties before it.

In Ruperto v. Torres (100 Phil. 1098 [1957], unreported), the Court had occasion to rule on the
functions of an investigatory body with the sole power of investigation. It does not exercise judicial functions
and its power is limited to investigating the facts and making findings in respect thereto. The Court laid down
the test of determining whether an administrative body is exercising judicial functions or merely investigatory
functions: Adjudication signifies the exercise of power and authority to adjudicate upon the rights and
obligations of the parties before it. Hence, if the only purpose for investigation is to evaluate evidence
submitted before it based on the facts and circumstances presented to it, and if the agency is not authorized
to make a final pronouncement affecting the parties, then there is an absence of judicial discretion and
judgment.

FACTS:
 A complaint was filed against Ruperto,a government official, charging him with disloyalty to service,
partiality, favoritism, violation of his oath of office, and corruption.
 A copy of the complaint was submitted to the Integrity Board.
 The Board found, after hearing, that the charges were sufficiently established and concluded that
Ruperto made use of his public office for his personal interests.
 The Board recommended that Ruperto be given a warning, and any repetition will have greater
consequences.
 The Integrity Board was created by EO 318 and was succeeded by the Presidential Complaints and
Action Commission, which vested said board with the power to “proceed to a thorough and
complete investigation of any specific case of graft, corruption, dereliction of duty or irregularity in
office, and to submit to the President the record of such investigation together with its finding and
recommendation.”
 R filed a complaint for certiorari against the Integrity Board.

ISSUE + RULING: W/N the Integrity Board or PCAC was exercising quasi-judicial functions - NO

 The Investigatory Board’s power is limited to investigating the facts and making findings in respect
thereto
 The board neither adjudicates upon nor determines the rights and interests or duties of
parties
 After an investigation by the Integrity Board, the officer that ultimately passes upon and adjudicates
the rights of the parties is the President and not the board, or its successor Presidential Complaints
and Action Commission
 While it is true that the board, in performing its duties and exercising its functions may exercise what
is known as judicial discretion since it evaluates the evidence submitted to it on the facts and
circumstances presented, such judicial discretion is only for the purpose of evaluation and for the
determination of disputed facts
 Not every function wherein judgment and discretion are exercised is a judicial function
 The test of judicial functions is not the exercise of judicial discretion, but the power and
authority to adjudicate upon the rights and obligations of parties before it
 As the Board lacks the power and authority to adjudicate upon the matters submitted to it for
investigation and make final pronouncement thereon, the second requisite for availability of the
action of certiorari is wanting