Case Digest (G.R. No. L-20368)
Facts:
The case involves Crispin Bongcawil as the petitioner and the Provincial Board of Lanao del Norte, among others, as respondents. The events leading to this case began on March 7, 1960, when a complaint was filed by Victorio Dy against Bongcawil, who was serving as the Mayor of Maigo, Lanao del Norte. The complaint alleged various irregularities in Bongcawil's conduct as mayor. Following the complaint, Governor Mohamad Ali Dimaporo suspended Bongcawil from office for a period of 30 days. The Provincial Board of Lanao del Norte proceeded to hear the complaint, during which both the complainant and Bongcawil presented their evidence. After the hearing, the individual members of the board prepared their opinions, with two members favoring exoneration and one recommending conviction. These opinions were shared with Bongcawil, but the complainant did not appeal, rendering the opinions final.
However, on September 7, 1962, nearly two years after the initial complaint, the newl...
Case Digest (G.R. No. L-20368)
Facts:
1. Filing of Complaint and Suspension:
- On March 7, 1960, Victorio Dy filed a complaint with the Provincial Board of Lanao del Norte against Crispin Bongcawil, the Mayor of Maigo, Lanao del Norte, alleging irregularities in his official capacity.
- As a result, Governor Mohamad Ali Dimaporo suspended Bongcawil from office for 30 days.
2. Hearing and Submission for Decision:
- The complaint was set for hearing after Bongcawil filed his answer. Both parties submitted oral and documentary evidence.
- The case was then submitted to the Provincial Board for decision.
3. Drafting of Decision:
- The Provincial Board passed a resolution designating Vice Governor Valerio V. Rovira to draft the decision based on the evidence submitted.
- Rovira submitted the draft decision in August 1961 for deliberation by the board.
4. Change in Board Composition:
- Before the board could finalize the decision, Vice Governor Rovira and Board Member Bienvenido L. Padilla vacated their positions after launching candidacies for congressman in the 1961 elections.
- Arsenio A. Quibranza and Sheik Cosain Ali Usman were appointed to fill the vacancies.
5. Final Decision by New Board:
- On September 7, 1962, the newly constituted Provincial Board convened and unanimously adopted the decision prepared by former Vice Governor Rovira, which recommended Bongcawil's dismissal from office.
- Bongcawil was informed of the decision but failed to appeal to the Office of the President as required by law.
6. Petition for Certiorari:
- Bongcawil filed a petition for certiorari, arguing that the decision of the new board was null and void due to grave abuse of discretion and violation of law.
Issue:
- Whether the Provincial Board of Lanao del Norte acted with grave abuse of discretion and in violation of law in rendering the decision on September 7, 1962.
- Whether Bongcawil's failure to exhaust administrative remedies (by not appealing to the Office of the President) bars him from filing the petition for certiorari.
- Whether the individual opinions of the former board members, which were not formally adopted, have binding effect.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court upheld the decision of the Provincial Board of Lanao del Norte, emphasizing the importance of exhausting administrative remedies and the proper exercise of authority by administrative bodies. The petition was denied, and no costs were awarded.