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...

Facts:

Appointment and Statutory Basis

• Julio Agcaoili was appointed justice of the peace of Laoag, Ilocos Norte on March 25, 1916, by the Governor-General under Act No. 2041.
• Act No. 2041, adopted on July 1, 1911, provided that justices of the peace and auxiliary justices hold office “during good behavior” and did not impose an age limit.

Legislative Changes and Controversial Amendment

• On March 17, 1923, the Philippine Legislature enacted Act No. 3107 which amended section 203 of the Administrative Code.
• The amendment introduced a proviso stating that justices and auxiliary justices “shall be appointed to serve until they have reached the age of sixty-five years.”
• Although the title of Act No. 3107 mentioned only “regulating the salaries of justices of the peace,” the body of the law contained provisions affecting their appointment and jurisdiction, raising issues on whether its subject matter was clearly expressed.

Order of Removal and Agcaoili’s Protest

• On April 9, 1923, the Undersecretary of Justice, Luis P. Torres, issued a letter directing Agcaoili to cease serving as justice of the peace on the ground of having attained age 65, in conformity with the amended provision.
• Agcaoili received the letter on April 26, 1923, via the clerk of the Court of First Instance.
• On April 28, 1923, Agcaoili submitted a formal protest asserting that:
• The appointment under Act No. 2041 was for “good behavior” without an age limitation.
• The amendment contained in Act No. 3107 was not intended to affect justices of the peace already appointed before its enactment.
• A further protest on July 7, 1923, detailed his position and the manner in which the order was enforced, including the threat of criminal prosecution if he did not surrender his office.
• Threats and acts of administrative pressure led to his forced delivery of office to Alberto Suguitan, the auxiliary justice, albeit under protest.

Petition for Writ of Quo Warranto and Subsequent Proceedings

• In response to the removal, Agcaoili filed a petition for a writ of quo warranto in the Court of First Instance on April 23, 1925, later amended on September 8, 1925.
• The petition sought to challenge the legality of his ouster and to secure his reinstatement as justice of the peace.
• The respondent, Alberto Suguitan, answered the petition by raising a defense of prescription (statute of limitations).

Judicial and Legislative Considerations

• The trial judge, Fermin Mariano, upheld the defense of prescription and denied the petition for the extraordinary legal remedy.
• On appeal, the case raised multiple legal questions:
• Whether the new age limit provision of Act No. 3107 could apply retroactively to appointments made under Act No. 2041.
• Whether Agcaoili’s action was barred by the statutory prescription under section 216 of the Code of Civil Procedure.
• Extensive discussion in the record included analysis of:
• The mandatory provision of the Jones Law that each Act must have a title clearly stating its subject matter.
• Judicial interpretations from cases such as Segovia vs. Noel and Central Capiz vs. Ramirez regarding legislative procedure and retroactive application.
• The proper interpretation of the punctuation and language in section 216 of the Code of Civil Procedure, particularly regarding actions against public officers.

Resolution on Reconsideration

• On February 26, 1926, a resolution for reconsideration was issued modifying the earlier decision.
• The resolution limited the scope of the decision to two primary grounds:
• Act No. 3107 cannot be applied to Agcaoili, following the doctrine in Segovia vs. Noel.
• The defense of limitation or prescription does not apply to the facts of this case.
• All remarks concerning the procedure followed by the Undersecretary of Justice were eliminated in the modified decision.

Issue:

• Whether Act No. 3107, with its provision limiting tenure to age 65, may be applied retroactively to justices of the peace who were appointed under Act No. 2041 with the mandate to serve “during good behavior.”
• Whether the remedy of quo warranto filed by Agcaoili is barred by the statute of limitations (the prescription defense) under section 216 of the Code of Civil Procedure.
• The proper interpretation of legislative enactments vis-à-vis the Jones Law requirement that an Act's title must clearly express its subject matter.
• Whether the administrative process used to oust Agcaoili—lacking due process and relying on threats—was lawful.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)