Facts:

The case of Manuel Arevalo vs. Clemente Dalandan originated from a quo warranto proceeding initiated by Arevalo, who sought to assume the role of municipal president of Las Pinas. The respondent in this matter, Clemente Dalandan, filed a petition asking the Judge of the Court of First Instance of Rizal to approve and transmit a bill of exceptions, which he had submitted in pursuit of an appeal against the decision of the lower court regarding the quo warranto case. The lower court had previously ruled on matters that pertained to the contest over the municipal presidency, concluding their proceedings with a ruling that dismissed Dalandan's challenges. Dalandan's counsel argued for the appealable nature of the judge’s refusal to certify the bill of exception

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Facts:

Parties and Background

• Manuel Arevalo initiated quo warranto proceedings for the office of municipal president of the town of Las Piñas.
• Clemente Dalandan, as respondent, became involved when counsel on his behalf filed a bill of exceptions in the lower court.
• The case is styled as Manuel Arevalo, Petitioner, versus Clemente Dalandan, Respondent, reflecting the underlying dispute stemming from the election matter.

Procedural Posture

• Counsel for Clemente Dalandan petitioned the Supreme Court for a writ of mandamus.
• The petition requested that the judge of the Court of First Instance of Rizal be ordered to approve, certify, and transmit to the Supreme Court the bill of exceptions.
• The intended purpose of transmitting the bill of exceptions was to prosecute an appeal against the decision rendered in the initial quo warranto proceedings.

Relevant Statutory and Legal Provisions

• Section 499 of the Code of Civil Procedure was cited as the basis for the writ of mandamus.
• Provisions of the Election Law and other pertinent laws governing election disputes for municipal offices played a central role in the case.
• Under these laws, resolutions concerning municipal offices are explicitly declared final and non-appealable.

Judicial Considerations

• A primary inquiry was whether the final ruling or order of the lower court judge in the contested quo warranto proceeding was appealable.
• The legal framework established by the Election Law rendered such resolutions as final, thus barring subsequent appeals.
• Consequently, the decision of the lower court judge to refuse the bill of exceptions was rooted in adherence to statutory provisions.

Issue:

Appealability of the Lower Court’s Decision

• Whether the final ruling or order in the quo warranto proceedings is subject to appeal in view of the applicable election laws.

Appropriateness of Issuing a Writ of Mandamus

• Whether this court should order the judge of the Court of First Instance of Rizal to approve, certify, and transmit the bill of exceptions filed by counsel for Dalandan for the purpose of appealing the decision.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)