Case Digest (G.R. No. 16887) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Miguel R. Cornejo v. Andres Gabriel (41 Phil. 188, decided November 17, 1920), the petitioner, Miguel R. Cornejo, was the duly elected municipal president of Pasay, Province of Rizal, serving a three-year term beginning October 16, 1919. On September 13, 1920, Provincial Governor Andres Gabriel, acting under Section 2188 of the Administrative Code (Act No. 2711), suspended Cornejo pending investigation of alleged neglect of duty, oppression and corruption. Governor Gabriel submitted written charges to the Provincial Board of Rizal—composed of Gabriel himself, Pedro Magsalin and Catalino S. Cruz—and commenced a summary inquiry without prior notice or formal hearing. Cornejo then filed an original petition for mandamus directly with the Supreme Court, praying (1) to enjoin the ongoing investigation by the provincial board, and (2) to compel Governor Gabriel to reinstate him as municipal president. The provincial board demurred for lack of jurisdiction to prevent them from compl Case Digest (G.R. No. 16887) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Proceedings
- Petitioner Miguel R. Cornejo, elected Municipal President of Pasay (term beginning October 16, 1919), was suspended September 13, 1920.
- Respondents: Andres Gabriel (Provincial Governor of Rizal) and the Rizal Provincial Board (Gabriel, Pedro Magsalin, Catalino S. Cruz).
- Petitioner sought mandamus to (a) restrain investigation of charges pending resolution of this case and (b) compel reinstatement.
- Respondents’ Pleadings
- Provincial Board demurred, asserting the court could not enjoin statutory compliance.
- Governor’s answer: complaints of maladministration received and investigated; suspension invoked under Administrative Code powers; board investigation ongoing.
- Applicable Law
- Administrative Code, Art. IV, Ch. 57, § 2188: Governor may investigate municipal officers; for “official integrity” charges may suspend pending board action; must file written charges within 10 days.
- §§ 2189–2191: Board trial procedure; timelines for hearing (within 15 days), dismissal, reprimand, or forwarding record to Executive Bureau.
- Philippine Bill of Rights (Jones Law, § 3): “No person shall be deprived of life, liberty or property without due process of law.”
Issues:
- Jurisdiction and Relief
- Can the Supreme Court enjoin a pending provincial board investigation?
- Is mandamus the appropriate remedy to compel reinstatement?
- Substantive Due Process
- Does temporary suspension by the provincial governor, without prior notice or hearing, violate the due process guarantee?
- Is a public office “property” subject to constitutional due process protection?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)