Does the decision of the Supreme Court in Carpio vs Secretary of the Interior abandon the ruling in Villena vs Executive Secretary?
Answer: It is an improvement because the Presidential power of control over the Executive Branch of the government, according to the Supreme Court in Carpio vs Executive Secretary, extends over all executive officers from Cabinet Secretary to the lowliest clerk and has been held to mean “the power of the President to alter or modify or nullify or set aside what a subordinate officer had done in the performance of his duties and to substitute the judgment of the former to the latter.” (Suarez Political Law Review)