Almonte v.

Vasquez

Facts:

This is a case wherein respondent Ombudsman, requires petitioners Nerio Rogado and Elisa Rivera, as chief
accountant and record custodian, respectively, of the Economic Intelligence and Investigation Bureau (EIIB) to
produce "all documents relating to Personal Services Funds for the year 1988" and all evidence such as vouchers
from enforcing his orders.

Petitioner Almonte was formerly Commissioner of the EIIB, while Perez is Chief of the EIIB's Budget and Fiscal
Management Division. The subpoena duces tecum was issued by the Ombudsman in connection with his
investigation of an anonymous letter alleging that funds representing savings from unfilled positions in the EIIB had
been illegally disbursed. The letter, purporting to have been written by an employee of the EIIB and a concerned
citizen, was addressed to the Secretary of Finance, with copies furnished several government offices, including the
Office of the Ombudsman.

May be erased: [The letter reads in pertinent parts: that the EIIB has a syndicate headed by the Chief of Budget
Division who is manipulating funds and also the brain of the so called "ghost agents" or the "Emergency Intelligence
Agents" (EIA); that when the agency had salary differential last Oct '88 all money for the whole plantilla were
released and from that alone, Millions were saved and converted to ghost agents of EIA; Almost all EIIB agents
collects payroll from the big time smuggler syndicate monthly and brokers every week for them not to be
apprehended.]

In his comment on the letter-complaint, petitioner Almonte denied all the allegations written on the anonymous
letter. Petitioners move to quash the subpoena and the subpoena duces tecum but was denied.

Disclosure of the documents in question is resisted with the claim of privilege of an agency of the government on
the ground that "knowledge of EIIB's documents relative to its Personal Services Funds and its plantilla . . . will
necessarily [lead to] knowledge of its operations, movements, targets, strategies, and tactics and the whole of its
being" and this could "destroy the EIIB."

Issue:

Whether petitioners can be ordered to produce documents relating to personal services and salary vouchers of EIIB
employees on the plea that such documents are classified without violating their equal protection of laws.

Held:

YES. At common law a governmental privilege against disclosure is recognized with respect to state secrets bearing
on military, diplomatic and similar matters and in addition, privilege to withhold the identity of persons who furnish
information of violation of laws. In the case at bar, there is no claim that military or diplomatic secrets will be
disclosed by the production of records pertaining to the personnel of the EIIB. Indeed, EIIB's function is the gathering
and evaluation of intelligence reports and information regarding "illegal activities affecting the national economy,
such as, but not limited to, economic sabotage, smuggling, tax evasion, dollar salting." Consequently, while in cases
which involve state secrets it may be sufficient to determine from the circumstances of the case that there is
reasonable danger that compulsion of the evidence will expose military matters without compelling production, no
similar excuse can be made for a privilege resting on other considerations.

The Ombudsman is investigating a complaint that several items in the EIIB were filled by fictitious persons and that
the allotments for these items in 1988 were used for illegal purposes. The plantilla and other personnel records are
relevant to his investigation as the designated “protectors of the people” of the Constitution.
Nor is there violation of petitioners' right to the equal protection of the laws. Petitioners complain that "in all forum
and tribunals . . . the aggrieved parties . . . can only hale respondents via their verified complaints or sworn
statements with their identities fully disclosed," while in proceedings before the Office of the Ombudsman
anonymous letters suffice to start an investigation. In the first place, there can be no objection to this procedure
because it is provided in the Constitution itself. In the second place, it is apparent that in permitting the filing of
complaints "in any form and in a manner," the framers of the Constitution took into account the well-known
reticence of the people which keep them from complaining against official wrongdoings. As this Court had occasion
to point out, the Office of the Ombudsman is different from the other investigatory and prosecutory agencies of the
government because those subject to its jurisdiction are public officials who, through official pressure and influence,
can quash, delay or dismiss investigations held against them. On the other hand complainants are more often than
not poor and simple folk who cannot afford to hire lawyers.

Finally, it is contended that the issuance of the subpoena duces tecum would violate petitioners' right against self-
incrimination. It is enough to state that the documents required to be produced in this case are public records and
those to whom the subpoena duces tecum is directed are government officials in whose possession or custody the
documents are. Moreover, if, as petitioners claim the disbursement by the EII of funds for personal service has
already been cleared by the COA, there is no reason why they should object to the examination of the documents
by respondent Ombudsman.
Nuñez v. Sandiganbayan

January 30, 1982

G.R. No. L-50581-50617

FACTS:

Petitioner in this certiorari and prohibition proceeding assails the validity of the Presidential Decree creating the
Sandiganbayan, He was accused before such respondent Court of estafa through falsification of public and
commercial document committed in connivance with his other co-accused, all public officials, in several cases. The
informations were filed respectively on February 21 and March 26, 1979. Thereafter, on May 15 of that year, upon
being arraigned, he filed a motion to quash on constitutional and jurisdictional grounds. A week later respondent
Court denied such motion. There was a motion for reconsideration filed the next day; it met the same fate. Hence
this petition for certiorari and prohibition It is the claim of petitioner that Presidential Decree No. 1486, as
amended, creating the respondent Court is violative of the due process, equal protection, and ex post facto clauses
of the Constitution.

ISSUE: Is Presidential Decree No. 1486 violative of the due process, equal protection and ex post facto clauses of
the Constituiton, thus decraling it unconstitutional?

HELD:

No, The petition then cannot be granted. The unconstitutionality of such Decree cannot be adjudged. Those
adversely affected may under such circumstances invoke the equal protection clause only if they can show that the
governmental act assailed, far from being inspired by the attainment of the common weal was prompted by the
spirit of hostility, or at the very least, discrimination that finds no support in reason For the principle is that equal
protection and security shall be given to every person under circumstances which, if not Identical, are analogous. If
law be looked upon in term of burden or charges, those that fall within a class should be treated in the same
fashion, whatever restrictions cast on some in the group equally binding on the rest.

An ex post facto law is one which: (1) makes criminal an act done before the passage of the law and which was
innocent when done, and punishes such an act; (2) aggravates a crime, or makes it greater than it was, when
committed; (3) changes the punishment and inflicts a greater punishment than the law annexed to the crime
when committed; (4) alters the legal rules of evidences, and authorizes conviction upon less or different testimony
than the law required at the time of the commission to regulate civil rights and remedies only, in effect imposes
penalty or deprivation of a right for something which when done was lawful, and (6) deprives a person accused of a
crime of some lawful protection to which he has become entitled, such as the protection of a former conviction or
acquittal, or a proclamation of amnesty.” Even the most careful scrutiny of the above definition fails to sustain the
claim of petitioner.

This court has had frequent occasion to consider the requirements of due process of law as applied to criminal
procedure, and, generally speaking, it may be said that if an accused has been heard in a court of competent
jurisdiction, and proceeded against under the orderly processes of law, and only punished after inquiry and
investigation, upon notice to him, with an opportunity to be heard, and a judgment awarded within the authority of
a constitutional law, then he has had due process of law.” This Court holds that petitioner has been unable to make
a case calling for a declaration of unconstitutionality of Presidential Decree No. 1486 as amended by Presidential
Decree No. 1606.

Petition dismissed. No costs.

Chua vs. CSC and NIA [G.R. No. 88979. February 07, 1992]

Ponente: PADILLA, J.

FACTS:

Republic Act No. 6683 provided benefits for early retirement and voluntary separation from the government service
as well as for involuntary separation due to reorganization. Deemed qualified to avail of its benefits are those
enumerated in Sec. 2 of the Act. Petitioner Lydia Chua believing that she is qualified to avail of the benefits of the
program, filed an application with respondent National Irrigation Administration (NIA) which, however, denied the
same; instead, she was offered separation benefits equivalent to one half (1/2) month basic pay for every year of
service commencing from 1980, or almost fifteen (15) years in four (4) successive governmental projects. A recourse
by petitioner to the Civil Service Commission yielded negative results, citing that her position is co-terminous with
the NIA project which is contractual in nature and thus excluded by the enumerations under Sec.3.1 of Joint DBM-
CSC Circular Letter No. 89-1, i.e. casual, emergency, temporary or regular employment. Petitioner appealed to the
Supreme Court by way of a special civil action for certiorari.

ISSUE:

Whether or not the petitioner is entitled to the benefits granted under Republic Act No. 6683.

HELD:

YES. Petition was granted.

RATIO:

Petitioner was established to be a co-terminous employee, a non-career civil servant, like casual and emergency
employees. The Supreme Court sees no solid reason why the latter are extended benefits under the Early Retirement
Law but the former are not. It will be noted that Rep. Act No. 6683 expressly extends its benefits for early retirement
to regular, temporary, casual and emergency employees. But specifically excluded from the benefits are uniformed
personnel of the AFP including those of the PC-INP. It can be argued that, expressio unius est exclusio alterius but
the applicable maxim in this case is the doctrine of necessary implication which holds that “what is implied in a
statute is as much a part thereof as that which is expressed”.

[T]he Court believes, and so holds, that the denial by the respondents NIA and CSC of petitioner’s application for
early retirement benefits under R.A. No. 6683 is unreasonable, unjustified, and oppressive, as petitioner had filed
an application for voluntary retirement within a reasonable period and she is entitled to the benefits of said law. In
the interest of substantial justice, her application must be granted; after all she served the government not only for
two (2) years — the minimum requirement under the law but for almost fifteen (15) years in four (4) successive
governmental projects.
TIU V. CA (1999) | EQUAL PROTECTION CLAUSE (G.R. No. 127410, 37 SCRA 99, January 28, 1971)

DOCTRINES:

The Constitution does not require absolute equality among residents. It is enough that all persons under like
circumstances or conditions are given the same privileges and required to follow the same obligations.

The classification based on a valid and reasonable standard does not violate the equal protection clause.

FACTS:

RA 7227 seeks to accelerate the conversion of military reservations into other productive uses. Section 12 thereof
created the Subic Special Economic Zone (SSEZ), which includes the City of Olongapo, Municipality of Subic and the
lands occupied by the Subic Naval Base and granted special privileges.

Thereafter, EO 97 was issued to clarify the application of the incentives provided by RA 7227. Sec. 1 of EO 97 provides
for the tax and duty-free importations shall only be applied raw materials, capital goods and equipment brought in
by business enterprises into the SSEZ. Except for these items, importations of other goods into the SSEZ, whether by
business enterprises, resident individuals are subject to the taxes and duties under Philippine laws. The exportation
or removal of tax and duty free goods from the territory of the SSEZ to other parts of the Philippines shall be subject
to duties and taxes under Philippine laws.

Section 1.1 thereof grants the enjoyment of the tax and duty incentives to the business and enterprises and residents
within the presently fenced-in former Subic Naval Base only. It excludes the the first two component cities as
provided for by Sec. 12 of RA 7227.

ISSUES:

Whether EO 97-A violates the equal protection of the laws?

RULING:

No, EO 97-A is not violative of the equal protection of the laws.

The fundamental right of equal protection of the laws is not absolute, but is subject to reasonable classification.

Classification, to be valid, must (1) rest on substantial distinctions, (2) be germane to the purpose of the law, (3) not
be limited to existing conditions only, and (4) apply equally to all members of the same class.

RA 7227 aims primarily to accelerate the conversion of military reservations into productive uses.

The Government provides enticements as to persuade and attract investors to pour in capital with the said military
bases. Among such enticements are: (1) a separate customs territory within the zone, (2) tax-and-duty-free
importations, (3) restructured income tax rates on business enterprises within the zone, (4) no foreign exchange
control, (5) liberalized regulations on banking and finance, and (6) the grant of resident status to certain investors
and of working visas to certain foreign executives and workers.

The purpose of the law is to convert former military base to productive use for the benefit of the Philippine economy.
Hence, there was no reasonable basis to extend the tax incentives in RA 7227.
DeGuzman v. COMELEC (GR No. 129118. July 19, 2000)

FACTS:

This is a petition for certiorari and prohibition with urgent prayer for the issuance of a writ of preliminary injunction
and temporary restraining order, assailing the validity of Section 44 of Republic Act No. 8189 (RA 8189) otherwise
known as "The Voters Registration Act of 1996".

SEC. 44. Reassignment of Election Officers. - No Election Officer shall hold office in a particular city or municipality
for more than four (4) years. Any election officer who, either at the time of the approval of this Act or subsequent
thereto, has served for at least four (4) years in a particular city or municipality shall automatically be reassigned by
the Commission to a new station outside the original congressional district.

Petitioners, who are either City or Municipal Election Officers, were reassigned to different stations by the COMELEC.

Petitioners contend that the said law is unconstitutional because it violates the equal protection clause guaranteed
by the 1987 Constitution because it singles out the City and Municipal Election Officers of the COMELEC as prohibited
from holding office in the same city or municipality for more than four (4) years. They maintain that there is no
substantial distinction between them and other COMELEC officials, and therefore, there is no valid classification to
justify the objective of the provision of law under attack.

ISSUE:

Whether or not Section 44 of RA 8189 violates the equal protection clause.

HELD:

No.

The singling out of election officers in order to "ensure the impartiality of election officials by preventing them from
developing familiarity with the people of their place of assignment" does not violate the equal protection clause of
the Constitution.

Lutz vs. Araneta: "the legislature is not required by the Constitution to adhere to a policy of all or none".

This is so for underinclusiveness is not an argument against a valid classification. It may be true that all the other
officers of COMELEC referred to by petitioners are exposed to the same evils sought to be addressed by the statute.
However, in this case, it can be discerned that the legislature thought the noble purpose of the law would be
sufficiently served by breaking an important link in the chain of corruption than by breaking up each and every link
thereof. Verily, under Section 3(n) of RA 8189, election officers are the highest officials or authorized representatives
of the COMELEC in a city or municipality. It is safe to say that without the complicity of such officials, large-scale
anomalies in the registration of voters can hardly be carried out.

The petition is dismissed and upheld the constitutionality of Section 44 of RA 8189.

 Irene Cruz v. Commission on Audit (COA)

Oct. 23, 2001 | Pardo | Equal Protection

PETITIONER: Irene Cruz, et al. in their own behalf and in representation of their
co-employees, numbering 330 in the Sugar Regulatory Administration

RESPONDENTS: Commission on Audit (COA)

SUMMARY:

The Sugar Regulatory Administration (SRA), a gov’t owned corporation, adopted

resolutions since 1963 granting the payment of social amelioration benefits (SAB)
to all its employees sourced from corporate funds. In 1989, RA No. 6758 took
effect. In 1994, Ms Villarosa, the Resident Auditor of the Commission on Audit in
the SRA, upon examining the accounts of the SRA and pursuant to the said Act,
questioned the legality of the payment of SAB to all SRA employees. The DBM
also ruled that the SAB had no legal basis and was violative of RA No. 6758.
Accordingly, COA suspended the SAB. The affected employees appealed to the
Office of the President for the continuation of the grant of SAB. The Office of the
President, thru its Executive Secretary, issued a 1st indorsement granting post
facto approval or ratification of the SAB. The COA then allowed payment of the
SAB but only to those SRA employees hired before Oct. 31, 1989. Other
employees remained not entitled to the said benefits. The issue in this case is
W/N the classification of SRA employees based on the date of hiring (i.e. those
hired before and those after Oct. 31, 1989) is a valid classification. The Court
ruled in the negative. It held that the classification made by the COA as to who
were entitled to the SAB and who were not based merely on the date of hiring,
i.e., those hired before and those after Oct. 31, 1989, has no legal basis. The date
of hiring of an employee cannot be considered a substantial distinction. Any
distinction among employees must be based on substantial distinctions, that
is, level or rank, degree of difficulty and amount of work. The employees, based
on the title or position, were exposed to the same type of work, regardless of the
date they were hired. The petition is therefore granted and the COA Decision is
set aside.
DOCTRINE: The date of hiring of an employee cannot be considered a substantial
distinction. The employees, based on the title or position, were exposed to the
same type of work, regardless of the date they were hired. Any distinction among
employees must be based on substantial distinctions, that is, level or rank,
degree of difficulty and amount of work.

FACTS:

1. This case is an appeal of the decision of the COA, denying the grant of social amelioration benefits to
employees of the Sugar Regulatory Administration (SRA) hired after Oct. 31, 1989.
 2. The SRA, a gov’t owned corporation, adopted resolutions since 1963 granting the payment of social
amelioration benefits (SAB) to all its employees sourced from corporate funds.
3. RA No. 6758 took effect in July 1989.
4. In May 1994, Ms. Villarosa, the Resident Auditor of the Commission on Audit in the SRA, examined the
accounts of SRA. Pursuant to Sec. 12 of RA No. 6758, which provides that, “such other additional
compensation, in cash or kind, being received by incumbents only as of July 1, 1989, not integrated into the
standardized rates shall continue to be authorized,” Ms. Villarosa questioned the legality of the payment of
the SAB to all SRA employees.
5. The Dept. of Budget & Management (DBM) also ruled that the grant of SAB had no legal basis and was in
violation of RA No. 6758.
6. Accordingly, the COA suspended the payment of SAB to all SRA employees. The affected employees then
appealed to the Office of the Pres. for the continuation of the grant of SAB.
7. The COA claimed that upon effectivity of RA No. 6758, the SAB was no longer allowed unless there was
prior authority from the DBM or Office of the Pres. or a legislative issuance.
8. The Office of the Pres., thru Exec Secretary Ruben Torres, issued a 1st indorsement, granting post facto
approval or ratification of the SAB to SRA employees.
9. The COA then allowed payment of the SAB but only to those SRA employees hired before Oct. 31, 1989.
Other employees remained not entitled to the said benefits.

ISSUES:

1. W/N the classification of SRA employees based on the date of hiring (i.e. those hired before and those
after Oct. 31, 1989) is a valid classification. [NO]

RATIO:

1. The Court held that the classification made by the COA as to who were entitled to the SAB and who were
not based merely on the date of hiring, i.e., those hired before and those after Oct. 31, 1989, has no legal
basis.
2. The date of hiring of an employee cannot be considered a substantial distinction. The employees, based
on the title or position, were exposed to the same type of work, regardless of the date they were hired. The
date of hiring is not among those factors to be taken into consideration in the fixing of compensation or
granting of benefits.
3. Any distinction among employees must be based on substantial distinctions, that is, level or rank, degree
of difficulty and amount of work. To discriminate based solely on the date if hiring is to run against the
progressive and social policy of the law.
4. ‘When the law does not distinguish, the courts should not distinguish’ also applies in this case.

DISPOSITION:

The Court GRANTS the petition and sets aside the COA Decision.
Lopez v CA (G.R. 144573)

Facts:

This is a petition for certiorari for the decision which granted Liggayu (private respondent) a prayer for the issuance
of a Writ of Preliminary Mandatory Injunction enjoining the implementation of his suspension pending appeal.

Atty. Romeo A. Liggayu, Manager of the Legal Department and Resident Ombudsman of the Philippine Charity
Sweepstakes Office (PCSO), was administratively charged before the Office of the Ombudsman with: (1) Violation of
Republic Act No. 6770 (Ombudsman Act of 1989), for issuing a subpoena without authority in relation with a case
entitled “FACT-FINDING AND INTELLIGENCE BUREAU v MANUEL MORATO”. (2) Complicity in the anomalous
contracts entered into by PCSO and Golden Lion Films for the production of 1,092 episodes of Ang Pangarap Kong
Jackpot, subject matter of OMB-0-99-0571 and 0572 entitled, FFIB vs. MANUEL MORATO, et al. and OMB-ADM-0-
99-0254 entitled, FFIB vs. ISRAEL G. ESTRELLA.

The Office of the Ombudsman dismissed the charge against Liggayu on the anomalous contracts of the PCSO but
found him guilty of Conduct Prejudicial To The Best Interest Of The Service violation of R.A. No 6770 on the ground
that it is excess of his authority as Resident Ombudsman of PCSO. The Office of the Ombudsman in finality, imposed
the penalty of 6 months and 1day suspension without pay.

At the case at bar, a petition for review was filed by Atty. Liggayu before the CA to restrain the execution of the
decision of the Office of the Ombudsman, however, Lopez executed the suspension of Atty. Liggayu as the order of
the Office of Ombudsman. Lopez alleged that in Section 7 Rule III of the Rules of Procedure of the Office of the
Ombudsman and Section 27 of R.A. No. 6770, directive orders from the Office of the Ombudsman must be effective
immediately. Moreover, in all administrative disciplinary cases, orders, directives or decisions of the Office of the
Ombudsman may be appealed to the Supreme Court by filing a petition for certiorari within ten (10) days from
receipt of the written notice of the order, directive or decision or denial of the motion for reconsideration in
accordance with Rule 45 of the Rules of Court. Hence, this petition:

ISSUE:

Whether the Lopez’s claim that the stay of execution pending appeal from the order of the Office Ombudsman is
violative of the equal protection clause

RULING: Yes. (Petition was dismissed)

The Court finds unavailing the claim of petitioners that the stay of execution pending appeal from the order, directive
or decision of the Office of the Ombudsman violates the equal protection clause for being unfair to government
employees charged under the Civil Service Law, where the decisions in disciplinary cases are immediately executory.
The legislature has seen fit to grant a stay of execution pending appeal from disciplinary cases where the penalty
imposed by the Office of the Ombudsman is not public censure, reprimand, or suspension of not more than one
month, or a fine not equivalent to 1month salary. Courts may not, in the guise of interpretation, enlarge the scope
of a statute and include therein situations not provided or intended by the lawmakers. An omission at the time of
enactment, whether careless or calculated, cannot be judicially supplied notwithstanding that later wisdom may
recommend the inclusion.

The penalty imposed on Atty. Liggayu for Conduct Prejudicial To The Best Interest of The Service was six (6) months
and one (1) day suspension without pay. Considering that private respondent appealed from the decision of the
Office of the Ombudsman, the stay of execution of the penalty of suspension should therefore issue as a matter of
right.
RATIO:

In Lapid v. CA, it was held that only orders, directives or decisions of the Office of the Ombudsman in administrative
cases imposing the penalty of public censure, reprimand, or suspension of not more than one month, or a fine not
equivalent to one month salary shall be final and unappealable hence, immediately executory. In all other
disciplinary cases where the penalty imposed is other than public censure, reprimand, or suspension of not more
than one month, or a fine not equivalent to one month salary, the law gives the respondent the right to appeal.

In these cases, the order, directive or decision becomes final and executory only after the lapse of the period to
appeal if no appeal is perfected, or after the denial of the appeal from the said order, directive or decision. It is only
then that execution shall perforce issue as a matter of right. The fact that the Ombudsman Act gives parties the right
to appeal from its decisions should generally carry with it the stay of these decisions pending appeal. Otherwise, the
essential nature of these judgments as being appealable would be rendered nugatory.
Philippine Rural Electric Cooperatives Association, Inc. vs. Secretary of the Department of the Interior and Local
Government

Fact:

a class suit was filed by petitioners in their own behalf and in behalf of other electric cooperatives organized and
existing under P.D. No. 269, as amended, and registered with the National Electrification Administration (NEA).
Accordingly, petitioners enjoys Assistance; Exemption from Taxes, Imposts, Duties, Fees; Assistance from the
National Power Corporation. Petitioners contend that they are exempt from payment of local taxes, including
payment of real property tax. With the passage of the Local Government Code, however, they allege that their tax
exemptions have been invalidly withdrawn. In particular, petitioners assail Sections 193 and 234 of the Local
Government Code on the ground that the said provisions discriminate against them, in violation of the equal
protection clause. Further, they submit that the said provisions are unconstitutional because they impair the
obligation of contracts between the Philippine Government and the United States Government.

Issue:

Whether the assailed provisions of the Local Government Code violates the rights of the Petitioners to the Equal
Protection clause by unreasonable classifying them and withdrawing their Tax exemption

Held:

There is No Violation of the Equal Protection Clause. The equal protection clause under the Constitution means that
“no person or class of persons shall be deprived of the same protection of laws which is enjoyed by other persons
or other classes in the same place and in like circumstances.” Thus, the guaranty of the equal protection of the laws
is not violated by a law based on reasonable classification. The court hold that there is reasonable classification
under the Local Government Code to justify the different tax treatment between electric cooperatives covered by
P.D. No. 269, as amended, and electric cooperatives under R.A. No. 6938.

First, substantial distinctions exist between cooperatives under P.D. No. 269, as amended, and cooperatives under
R.A. No. 6938. These distinctions are manifest in at least two material respects which go into the nature of
cooperatives envisioned by R.A. No. 6938 and which characteristics are not present in the type of cooperative
associations created under P.D. No. 269, as amended.

Capital Contributions by Members

Extent of Government Control over Cooperatives

Second, the classification of tax-exempt entities in the Local Government Code is germane to the purpose of the law.
The Constitutional mandate that every local government unit shall enjoy local autonomy, does not mean that the
exercise of power by local governments is beyond regulation by Congress. Thus, while each government unit is
granted the power to create its own sources of revenue, Congress, in light of its broad power to tax, has the
discretion to determine the extent of the taxing powers of local government units consistent with the policy of local
autonomy.