ART. XVI, Section 6. The State Shall Establish: The Constitutional Commissions. All Three
ART. XVI, Section 6. The State Shall Establish: The Constitutional Commissions. All Three
ART. XVI, Section 6. The State Shall Establish: The Constitutional Commissions. All Three
concept and the PNP is a civilian agency. When conducive to public accountability. It shall
the President chose not to deal with Sec. Roxas submit to the President and the Congress an
and that PNP Chief and deals with someone else annual report on its personnel programs.
instead, that is the power of control that was in
play . He was not acting there as a Commander-
in-Chief, therefore bound by the chain of
command principle.