Title
Agcaoili vs. Suguitan
Case
G.R. No. 24806
Decision Date
Feb 13, 1926
Julio Agcaoili, appointed justice of the peace under tenure "during good behavior," challenged his removal under Act No. 3107, which imposed a mandatory retirement age. The Supreme Court ruled Act No. 3107 non-retroactive, reinstating Agcaoili, as quo warranto was not time-barred.
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Case Digest (G.R. No. 24806)

Facts:

Appointment of Julio Agcaoili:
Julio Agcaoili was appointed as justice of the peace of Laoag, Ilocos Norte, on March 25, 1916, under Act No. 2041, which provided that justices of the peace shall hold office "during good behavior."

Enactment of Act No. 3107:
On March 17, 1923, Act No. 3107 was enacted, amending the Administrative Code to provide that justices of the peace shall serve until they reach the age of 65 years. This Act did not mention retroactivity.

Notification of Removal:
On April 9, 1923, the Undersecretary of Justice notified Agcaoili, who was over 65, that he must cease to be a justice of the peace under Act No. 3107. Agcaoili protested, arguing that Act No. 3107 did not apply to justices appointed before its enactment.

Forced Ouster:
On July 7, 1923, Agcaoili, under threat of criminal prosecution, reluctantly surrendered his office to Alberto Suguitan, the auxiliary justice of the peace.

Filing of Quo Warranto:
Agcaoili filed a petition for quo warranto on April 23, 1925, seeking reinstatement. The trial court denied the petition, ruling that the action was barred by the one-year statute of limitations under Section 216 of the Code of Civil Procedure.

Issue:

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Ruling:

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Ratio:

  1. Non-Retroactivity of Act No. 3107: The Court emphasized that Act No. 3107, which introduced a mandatory retirement age, did not explicitly state it had retroactive effect. Therefore, it could not be applied to justices appointed under Act No. 2041, which guaranteed tenure "during good behavior."

  2. Statute of Limitations in Quo Warranto: The Court ruled that quo warranto is a prerogative writ, and statutes of limitation do not apply to such actions. Even if Section 216 of the Code of Civil Procedure were applicable, the one-year period had not started because Agcaoili was justified in waiting for a resolution of his protest.

  3. Constitutionality of Act No. 3107: Although the Court discussed the constitutionality of Act No. 3107, it ultimately considered the issue unnecessary for the resolution of the case, as the Act was found inapplicable to Agcaoili.

Conclusion:

The Supreme Court reversed the trial court’s decision and ordered Julio Agcaoili’s reinstatement as justice of the peace of Laoag, Ilocos Norte. The Court held that Act No. 3107 could not be applied retroactively and that the action for quo warranto was not barred by the statute of limitations.


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