04/02/2020 E-Library - Information At Your Fingertips: Printer Friendly [101] If at all, the factual circumstances surrounding the appointment may become material should the President make a last minute en masse “appointment” - as the term is understood under Section 15, Article VII – a day or two before the effectivity of the ban in a manner that unmistakably shows an abuse of presidential prerogative comparable or even worse than Aytona. [102] If at all, these factual circumstances may become material once an appointment is found to be technically valid. See footnote (preceding immediately). [103] G.R. No. 181559, October 2, 2009, 602 SCRA 580, 591-593. [104] CSC Resolution No. 010988 dated June 4, 2001, pertinently reads: NOW THEREFORE, the Commission, pursuant to its constitutional mandate as the control personnel agency of the government, hereby issues and adopts the following guidelines: xxxx 3. All appointments, whether original, transfer, reemployment, reappointment, promotion or demotion, except in cases of renewal and reinstatement, regardless of status, which are issued AFTER the elections, regardless of their dates of effectivity and/or date of receipt by the Commission, including its Regional or Field Offices, of said appointments or the Report of Personnel Actions (ROPA) as the case may be, shall be disapproved unless the following requisites concur relative to their issuance: a) The appointment has gone through the regular screening by the Personnel Selection Board (PSB) before the prohibited period on the issuance of appointments as shown by the PSB report or minutes of its meeting; b) That the appointee is qualified; c) There is a need to fill up the vacancy immediately in order not to prejudice public service and/or endanger public safety; d) That the appointment is not one of those mass appointments issued after the elections. 4. The term "mass appointments" refers to those issued in bulk or in large number after the elections by an outgoing local chief executive and there is no apparent need for their immediate issuance. [105] This case in turn cited pre-1987-Constitution cases: Quimsing v. Tajanglangit (1964); Davide v. Roces (1975); Aytona v. Castillo (1962); Rodriguez, Jr. v. Quirino (1963). [106] De Rama v. Court of Appeals, G.R. No. 131136, February 28, 2001, 353 SCRA 95, 102. elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/60717 68/75