Case Digest (G.R. No. 24806)
Facts:
The case of Julio Agcaoili vs. Alberto Suguitan was initiated in the Court of First Instance of Ilocos Norte, where Julio Agcaoili sought the extraordinary legal remedy of quo warranto against Alberto Suguitan. Agcaoili had been appointed as the justice of the peace for Laoag, Ilocos Norte, on March 25, 1916, by Governor-General Francis Burton Harrison, with the stipulation that he would hold the office "during good behavior" as per Act No. 2041. This act, effective from July 1, 1911, stated that justices of the peace would hold their positions during good behavior without an age limit. However, on March 17, 1923, the Philippine Legislature enacted Act No. 3107, which amended the Administrative Code and stipulated that justices of the peace would serve until the age of 65. Agcaoili, who was over 65 at the time, received a letter from the Undersecretary of Justice on April 9, 1923, ordering him to cease his duties due to his age. Despite his protests, he was compel...
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:
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."
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.
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.