Practice question
An agency issues a document headed Staff Guidance. It directs officials to deny all members of the public a license unless they comply with a newly created substantive requirement. The agency refuses to consider publication because the document is addressed to employees. Which is best?
- Every employee-addressed document is necessarily internal
- The external legal effect must be assessed; addressing staff does not make a new public obligation merely internal
- The heading alone controls
- No agency document can affect the public
- All guidance is automatically a statute
Legal references
- Tanada v. Tuvera, G.R. No. L-63915, December 29, 1986, main resolution: https://lawphil.net/judjuris/juri1986/dec1986/gr_l-63915_1986.html
- Republic v. Pilipinas Shell Petroleum Corporation, G.R. No. 173918, April 8, 2008, main opinion: https://lawphil.net/judjuris/juri2008/apr2008/gr_173918_2008.html
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