Case Digest (G.R. No. 108399)
Facts:
The case involves a petition for review on certiorari filed by Rafael M. Alunan III, in his capacity as Secretary of the Department of Interior and Local Government (DILG), along with several other petitioners, against respondents Robert Mirasol and others, including the Honorable Wilfredo D. Reyes, Presiding Judge of the Regional Trial Court, Branch 36, Metro Manila. The case arose from a decision dated January 19, 1993, by the Regional Trial Court of Manila, which nullified an order from the DILG that effectively canceled the general elections for the Sangguniang Kabataan (SK) scheduled for December 4, 1992, in the City of Manila. The DILG's order was based on the premise that elections previously held on May 26, 1990, were to be considered the first elections for the SK under the Local Government Code of 1991 (R.A. No. 7160). The Local Government Code, which took effect on January 1, 1992, mandated the establishment of a SK in every barangay, consisting of a chairman, ...
Case Digest (G.R. No. 108399)
Facts:
Background of the Case:
- The case involves a petition for review on certiorari of the decision dated January 19, 1993, by the Regional Trial Court (RTC) of Manila, Branch 36, which nullified an order of the Department of Interior and Local Government (DILG). The DILG order effectively canceled the general elections for the Sangguniang Kabataan (SK) scheduled for December 4, 1992, in the City of Manila.
Legal Framework:
- The Local Government Code of 1991 (R.A. No. 7160) established the Sangguniang Kabataan (SK) in every barangay, composed of a chairman, seven members, a secretary, and a treasurer. Section 532(a) of the Code mandated that the first elections for the SK be held 30 days after the next local elections. The Code took effect on January 1, 1992.
Election Timeline:
- The first local elections under the Code were held on May 11, 1992. On August 27, 1992, the Commission on Elections (COMELEC) issued Resolution No. 2499, providing guidelines for the SK elections scheduled for September 30, 1992. After two postponements, the elections were rescheduled for December 4, 1992.
DILG's Exemption Order:
- On September 18, 1992, the DILG, through Secretary Rafael M. Alunan III, issued a resolution exempting the City of Manila from holding SK elections on December 4, 1992. The DILG argued that the elections held on May 26, 1990, for the Kabataang Barangay (KB), the precursor of the SK, should be considered the first elections under the new Code.
RTC's Decision:
- Private respondents, representing the Katipunan ng Kabataan, filed a petition for certiorari and mandamus in the RTC to set aside the DILG resolution. The RTC ruled in favor of the respondents, holding that the DILG had no authority to exempt Manila from holding SK elections and that the exemption violated the equal protection clause of the Constitution.
Issue:
Authority of the DILG:
- Whether the Secretary of the DILG had the authority to exempt the City of Manila from holding SK elections on December 4, 1992, based on Section 532(d) of the Local Government Code.
Role of COMELEC:
- Whether the COMELEC could validly delegate the control and supervision of SK elections to the DILG, as provided in Resolution No. 2499.
Equal Protection Clause:
- Whether the exemption of the City of Manila from holding SK elections violated the equal protection clause of the Constitution.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court reversed the decision of the RTC and dismissed the case against the petitioners, upholding the authority of the DILG to exempt the City of Manila from holding SK elections on December 4, 1992.