Case Digest (G.R. No. L-59593)
Facts:
The case involves Francisco B. Asuncion, Jr. as the petitioner and Honorable Rosalio C. Segundo, in his capacity as Presiding Judge of the Court of First Instance of Pangasinan, Branch V, and Mayor Laureano S. Perez as the respondents. The events leading to this case began on February 1, 1980, when Laureano S. Perez was proclaimed elected. On July 15, 1981, Asuncion filed a special civil action for quo warranto against Perez, questioning his eligibility to hold office. Following this, on July 29, 1981, Perez filed a motion to dismiss the case, which Asuncion opposed on August 12, 1981. On September 8, 1981, Judge Segundo issued an order dismissing the quo warranto suit, stating that the action was filed out of time and that the court lacked jurisdiction over the case. Asuncion subsequently filed a motion for reconsideration, which was denied. The judge's order highlighted that the law required a quo warranto suit to be filed within...
Case Digest (G.R. No. L-59593)
Facts:
- Filing of the Quo Warranto Suit: On July 15, 1981, petitioner Francisco B. Asuncion, Jr. filed a special civil action (quo warranto) in the sala of respondent Judge Rosalio C. Segundo against private respondent Mayor Laureano S. Perez.
- Motion to Dismiss: On July 29, 1981, private respondent filed a motion to dismiss the quo warranto suit. Petitioner filed his opposition to the motion on August 12, 1981.
- Order of Dismissal: On September 8, 1981, respondent Judge issued an order dismissing the quo warranto suit, stating that the case was filed out of time and that the court had no jurisdiction over the matter.
- Proclamation of Private Respondent: Private respondent was proclaimed elected on February 1, 1980. The quo warranto suit was filed on July 15, 1981, well beyond the 10-day period prescribed by law for filing such actions.
- Motion for Reconsideration: Petitioner filed a motion for reconsideration, which was subsequently denied by the court.
Issue:
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Ruling:
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Ratio:
- Prescription of Quo Warranto Suit: Under Section 189 of the 1978 Election Code, a quo warranto suit contesting the election of an officer on the ground of ineligibility must be filed within 10 days after the proclamation of the election. The petitioner failed to comply with this requirement, as the suit was filed more than a year after the proclamation.
- Strict Compliance with Statutory Periods: The Court reiterated the principle that when a statute prescribes a specific period for filing an action, such period must be strictly followed. There is no room for interpretation or extension when the law is clear and unequivocal.
- Distinction Between Quo Warranto and Election Protest: The Court highlighted the distinction between a quo warranto suit and an election protest. A quo warranto suit cannot be converted into an election protest, and the prescribed period for filing a quo warranto suit must be adhered to.
- Jurisdiction: The court loses jurisdiction over a quo warranto suit if it is filed beyond the statutory period. Thus, the respondent Judge correctly dismissed the case for lack of jurisdiction.