classified as a court of justice within the meaning of the Constitution (Section 30, ArticleVIII), for it is merely an administrative body, may however exercise quasi-judicialfunctions insofar as controversies that by express provision of law come under itsjurisdiction. The difficulty lies in drawing the demarcation line between the duty whichinherently is administrative in character and a function which calls for the exercise ofthe quasi-judicial function of the Commission. In the same case, we also expressed theview that when the Commission exercises a ministerial function it cannot exercise thepower to punish for contempt because such power is inherently judicial in nature, as canbe clearly gleaned from the following doctrine we laid down therein:". . . In proceeding on this matter, it only discharged a ministerial duty; it did notexercise any judicial function. Such being the case, it could not exercise thepower to punish for contempt as postulated in the law, for such power isinherently judicial in nature. As this Court has aptly said: 'The power to punish forcontempt is inherent in all courts; its existence is essential to the preservation oforder in judicial proceedings, and to the enforcement of judgments, orders andmandates of courts, and, consequently, in the administration of justice' (SladePerkins vs. Director of Prisons, 58 Phil., 271; U.S. vs. Loo Hoe, 36 Phil., 867; InReSotto, 46 Off. Gaz., 2570; In Re Kelly, 3b Phil., 944). The exercise of thispower has always been regarded as a necessary incident and attribute of courts(Slade Perkins vs. Director of Prisons, Ibid.). Its exercise by administrative bodieshas been invariably limited to making effective the power to elicit testimony(People vs. Swena, 296 P., 271). And the exercise of that power by anadministrative body in furtherance of its administrative function has been heldinvalid (Langenberg vs. Lecker, 31 N.E., 190; In ReSims, 37 P., 135; Roberts vs.
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- Fall '19
- Law, Separation of Powers, Bench, liberal party