G.R. No. 170701 - Tua vs. Mangrobang

The case involves the Sangguniang Kabataan (SK) elections scheduled for December 4, 1992, in the City of Manila under the Local Government Code of 1991 (R.A. No. 7160).
Section 423 of the Code provides for the composition of the SK in every barangay, including the chairman, seven members, secretary, and treasurer.
Section 532(a) mandates that the first SK elections shall be held thirty (30) days after the next local elections. The Code took effect January 1, 1992; the first local elections under it were held May 11, 1992.
On August 27, 1992, the Commission on Elections (COMELEC) issued Resolution No. 2499, setting guidelines for the SK elections on September 30, 1992, under the direct control and supervision of the Department of Interior and Local Government (DILG) with technical assistance from COMELEC.
After two postponements, the SK elections were rescheduled for December 4, 1992.

Registration for the elections took place; 152,363 youth (ages 15-21) registered and 15,749 filed certificates of candidacy. The City Council appropriated funds for the elections.
On September 18, 1992, the DILG Secretary Rafael M. Alunan III issued a resolution exempting the City of Manila from holding the SK elections on December 4, 1992, based on the fact that Manila had already held Kabataang Barangay (KB) elections on May 26, 1990.
The exemption was justified under Section 532(d) of the Local Government Code, which allowed for the extension of the term of KB officials elected between January 1, 1988 and January 1, 1992, to coincide with the term of SK officials elected thereafter.
The DILG acted upon a letter from Joshue R. Santiago, then acting president of the KB City Federation of Manila, noting that prior KB elections in Manila should be considered the first SK elections under the Code.

On November 27, 1992, private respondents representing members of the Katipunan ng Kabataan filed a petition for certiorari and mandamus before the Regional Trial Court (RTC) of Manila to annul the DILG resolution.
They argued that the DILG had no authority to amend COMELEC resolutions calling for the SK elections nation-wide, and that the exemption violated equal protection.
The RTC, initially through Executive Judge Bernardo P. Pardo, enjoined the DILG from implementing the exemption and ordered pre-election activities to proceed for the December 4 elections.
After reraffling to Branch 36, RTC Judge Wilfredo D. Reyes nullified the DILG resolution on January 19, 1993, holding that:

Only the COMELEC had authority to enforce and administer election laws.
The COMELEC had already determined there were no prior KB elections sufficient to exempt Manila.
The exemption violated equal protection because while KB elections had been held in 5,000 barangays nationwide between 1988 and 1992, only Manila’s barangays were exempted from the 1992 SK elections.

The petitioners sought review, maintaining that Manila’s May 26, 1990 KB elections were valid and exempted under Section 532(d) of the Local Government Code.
They argued that the DILG Secretary was authorized to determine application of the exemption clause, relying on the legislative intent behind the Code.

Although the second SK elections were held on May 13, 1996 under R.A. No. 7808, the case’s justiciability was contested.
The Court recognized the case was not moot given the potential invalidity of officeholders elected in 1990 and the recurring nature of supervisory questions over SK elections.

Whether the Secretary of the Department of Interior and Local Government (DILG) had the authority to exempt the City of Manila from holding the December 4, 1992 SK elections pursuant to Section 532(d) of the Local Government Code.

Whether the Commission on Elections (COMELEC) can validly delegate the direct control and supervision of SK elections to the DILG with technical assistance from the COMELEC.

Whether the exemption of Manila’s barangays from holding the 1992 SK elections violates the constitutional guarantee of equal protection of the laws.