CA ruling upholds PNP courtesy resignation policy
The court stressed that senior PNP officials are presidential appointees, making the Office of the President the proper venue for such challenges.
The court stressed that senior PNP officials are presidential appointees, making the Office of the President the proper venue for such challenges.

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The Court of Appeals (CA) has upheld the legality of the Philippine National Police directive requiring senior officers to submit courtesy resignations as part of the government’s internal cleansing campaign.
In an 18-page ruling, the appellate court’s Tenth Division affirmed the Quezon City Regional Trial Court decision dismissing the petition filed by Police Colonels Julian Olonan and Rolando Portera, who sought to invalidate the 2023 memorandum.
The directive required colonels and generals to tender courtesy resignations amid a broader crackdown on officers allegedly linked to illegal drugs.
The CA ruled that the resignation letters submitted by the petitioners were valid and constituted a relinquishment of their positions and continued service.
It also rejected claims that the officers were denied due process or equal protection, noting their failure to exhaust administrative remedies before going to court.
The court stressed that senior PNP officials are presidential appointees, making the Office of the President the proper venue for such challenges.
Records showed Olonan and Portera submitted their courtesy resignations in June 2023 but later argued they intended only to vacate their posts, not leave the service.
The resignations were endorsed by the PNP and accepted by the Office of the President.
Both the trial court and the appellate court upheld the validity of the policy.
Earlier, the PNP Directorate for Personnel and Records Management received 942 courtesy resignations from 953 third-level police officials.