Case Digest (A.C. No. 10243) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case of Castillejos Consumers Association, Inc. (CASCONA) against various respondents arose from administrative issues concerning the management of Zambales II Electric Cooperative, Inc. (ZAMECO II) and followed a sequence of legal events that culminated in allegations of indirect contempt. Petitioner CASCONA, representing consumers from Castillejos, Zambales, made a complaint that led to the National Electrification Administration (NEA) issuing a removal resolution on November 24, 2004, against several board members led by Jose S. Dominguez for mismanagement and term expiration. Respondents appealed this decision to the Court of Appeals (CA), arguing that the NEA’s authority was curtailed by Republic Act No. 9136, known as the Electric Power Industry Reform Act (EPIRA). However, on March 13, 2009, the Supreme Court upheld NEA's authority over ZAMECO II, stating that despite the passage of EPIRA, the regulatory powers of NEA remained applicable, especially in administra
Case Digest (A.C. No. 10243) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Initiation of Proceedings
- CASCONA, an organization of electric consumers from Castillejos, Zambales, operates under the coverage of Zambales II Electric Cooperative, Inc. (ZAMECO II).
- Acting on a letter-complaint by CASCONA, the National Electrification Administration (NEA) issued a resolution on November 24, 2004, which removed respondents—including former board members and officers—from their positions for mismanagement of funds and expiration of their term of office.
- Appeal and Judicial Determinations
- Respondents (Dominguez, et al.) appealed the November 24, 2004 NEA resolution before the Court of Appeals (CA), asserting that Republic Act (R.A.) No. 9136 (the Electric Power Industry Reform Act or EPIRA) abrogated the NEA’s regulatory and disciplinary powers over electric cooperatives.
- On March 13, 2007, the CA upheld the authority of the NEA over ZAMECO II.
- Dissatisfied, respondents further appealed to the Supreme Court.
- On March 13, 2009, the Supreme Court rendered its decision in G.R. Nos. 176935-36, confirming that:
- The passage of the EPIRA did not affect the NEA’s power over administrative cases involving board members, officers, and employees of electric cooperatives.
- There was substantial evidence to support the removal of the board members (Dominguez, et al.).
- The issue regarding whether ZAMECO II was within the regulatory ambit of the Cooperative Development Authority (CDA) remained pending, pending proper conversion procedures as required by EPIRA.
- The case was remanded to the CA solely to determine the compliance with the conversion procedure, which involved the holding of a referendum and obtaining a simple majority vote.
- Developments Following the March 13, 2009 Decision
- Despite the ruling, further motions were filed:
- On May 4, 2009, respondents moved for reconsideration; the motion was denied on August 10, 2009.
- Respondents later filed a motion to set aside the entry of judgment based on the interlocutory nature of the March 13, 2009 decision; the Court granted this motion on February 3, 2010, recalling the entry of judgment since the case was still pending before the CA.
- In the interim, ZAMECO II was continued to be managed by an interim board under NEA supervision pursuant to the NEA resolution.
- On September 1, 2009, CDA Administrator for Luzon, Atty. Fulgencio Vigare, issued a memorandum declaring that the CDA should assume jurisdiction over ZAMECO II, based in part on statements made by the NEA during a House Committee Hearing on August 26, 2009.
- Following the memorandum, the CDA issued Resolution No. 262, S-2009 on October 19, 2009, and implemented Special Order 2009-304 on October 20, 2009, creating a team to engage with ZAMECO II’s management and pave the way for elections of new officers, alongside seeking the Department of Justice’s opinion on jurisdiction.
- On October 22, 2009, respondents Fidel Correa, Alicia Mercado, and Angelito Sacro entered the ZAMECO II premises and refused to leave. Later that night, PNP members and security guards assembled outside but were barred entry.
- The following day, on October 23, 2009, respondent P/Insp. Gerry Haduca and P/Insp. Robin Fugiran engaged the interim President of ZAMECO II for discussions, which led to a forceful entry by PNP members and security guards. The interim board refused to surrender management.
- On October 24, 2009, further attempts by former board members (Jose Dominguez, Jose Naseriv Dolojan, and Juan Fernandez) occurred, with tensions only de-escalating upon the intervention of Governor Amor Deloso.
- CASCONA consequently filed a petition for indirect contempt against the respondents, asserting that their acts pre-empted and disobeyed the Supreme Court’s March 13, 2009 decision.
Issues:
- Whether the acts of the respondents in attempting to take control of ZAMECO II and in their efforts to reinstate the former board members—despite the Supreme Court’s ruling that upheld their removal and the ongoing pending proceedings before the CA—amount to indirect contempt of court.
- Whether the issuance of the memorandum, resolutions, and special orders by CDA officials, as well as the subsequent physical and administrative takeover attempts, constitute unlawful interference with the court’s proceedings.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)