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“The President shall have the power to make appointments during the recess of the Congress, but such appointments shall be effective only until disapproval by the Commission on Appointments or until the next adjournment of the Congress.” – Section 16, Article VII, 1987 Constitution
Recess appointments are effective only
(a) until disapproval by the Commission on Appointments, or
(b) until the next adjournment of Congress, and never a day longer regardless of the nature of the session adjourned.