G.R. No. 127116 - David vs. Commission on Elections

Two petitions were filed challenging the upcoming barangay elections scheduled for May 12, 1997.
The petitions were filed on behalf of barangay officials who were elected on the second Monday of May 1994 and who contend that they were elected to a five‐year term under earlier laws (RA 6653/RA 6679) rather than the three‐year term provided in the Local Government Code (RA 7160).
Petitioner Alex L. David, in his capacity as Barangay Chairman of Barangay 77, Zone 7, Kalookan City, and as President of the Liga ng mga Barangay sa Pilipinas, filed his petition (G.R. No. 127116) on December 2, 1996 under Rule 65 of the Rules of Court seeking a prohibition against holding the May 1997 elections.
A second petition was filed by the Liga ng Mga Barangay Quezon City Chapter, represented by Bonifacio M. Rillon (G.R. No. 128039) on February 20, 1997, which sought to challenge:

The two cases were consolidated because they raised fundamentally the same issue regarding the duration of the term of office for barangay officials.
Procedural developments included:

The filing of comments by both the Solicitor General (supporting the petitioners’ contentions) and the Commission on Elections (defending its election schedule and resolutions).
The issuance by the Court of deadlines for comment, memoranda, and submissions by an amicus curiae (former Senator Aquilino Q. Pimentel, Jr.).
The denial of a petition for leave to intervene by another barangay official, as their interests were properly represented by the petitioners.

The evolution of the barangay election process from the Spanish colonial period to the American regime.
Various legislative enactments governing barangay elections:

RA 6653 and its subsequent amendment RA 6679, which originally provided for a five-year term and an indirect method of electing the punong barangay.
The Local Government Code of 1991 (RA 7160), which explicitly fixed the term of office of barangay officials at three years and mandated the direct election of the punong barangay by the electorate.

The apparent conflict between the older special laws (RA 6679) and the later Local Government Code regarding the term of office.

Under Section 2 of RA 6653 and the amended RA 6679, barangay officials were elected to a five-year term.
The historical practice and the specific provisions of those laws should govern the term of office.
The Local Government Code, being a general law, does not expressly or implicitly repeal RA 6679 as it applies to barangay officials.

The validity of the COMELEC Resolutions that set the barangay elections in May 1997, in accordance with RA 7160.
The consistency of the election results from May 9, 1994, where voters directly elected one punong barangay and seven kagawads.
The appropriateness of the three-year term limit provided in the Local Government Code.

The case also presented issues related to legislative intent regarding local autonomy and the planned synchrony of barangay elections with other electoral activities as indicated in the General Appropriations Act and RA 8189.

Direct and separate election of the punong barangay, contrary to the indirect method implied by RA 6679.
A voting process which yielded election results that supported the direct mandate of the elected barangay officials.

The later enactment of the Local Government Code (RA 7160) specifically provided for the direct election of barangay officials with a term fixed at three years.
The repealing clause within RA 7160, whereby any law inconsistent with its provisions was either repealed or modified.
Congressional appropriations and resolutions assumed that the election would follow the framework of RA 7160.

Whether the term of office of barangay officials is determined by RA 7160 (Local Government Code), fixing it at three years, or by the earlier RA 6679, which provided for a five-year term.
The issue involves interpreting conflicting statutory provisions where a later law appears to contradict an earlier, more specialized law.

Whether the provision in RA 7160 that establishes a three-year term for barangay officials is constitutional.
Petitioners argued that the Constitution, by leaving the term of barangay officials to be determined “by law,” implies that Congress cannot fix it at three years.
The Solicitor General and respondents contend that there is no constitutional prohibition on the legislature setting a three‐year term.

Whether petitioners are estopped from challenging the three‐year term since they ran and were elected under the provisions of RA 7160.
Consideration of whether the election results, obtained under the direct voting scheme mandated by the Local Government Code, bar petitioners from later contesting the validity of their term of office.