Case Digest (G.R. No. 136588) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In De Leon v. Esguerra, petitioners Alfredo M. De Leon (Barangay Captain) and Angel S. Salamat, Mario C. Sta. Ana, Jose C. Tolentino, Rogelio J. De la Rosa, and Jose M. Resurreccion (Barangay Councilmen of Barangay Dolores, Taytay, Rizal) filed an original action for writ of prohibition before the Supreme Court, En Banc. They were elected on May 17, 1982 under Batas Pambansa Blg. 222 with six-year terms ending June 7, 1988. On February 8, 1987, OIC Governor Benjamin B. Esguerra signed two memoranda, both antedated December 1, 1986, designating Florentino G. Magno as Barangay Captain and Remigio M. Tigas, Ricardo Z. Lacanienta, Teodoro V. Medina, Rosendo S. Paz, and Teresita L. Tolentino as Councilmen to replace petitioners. The memos were disseminated February 9, 1987. Petitioners moved to declare these memoranda void, arguing that their six-year term had not expired and that with the March 25, 1986 Provisional Constitution superseded by the 1987 Constitution (ratified February Case Digest (G.R. No. 136588) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Election and Terms
- On May 17, 1982, Alfredo M. De Leon was elected Barangay Captain and petitioners Angel S. Salamat, Mario C. Sta. Ana, Jose C. Tolentino, Rogelio J. de la Rosa and Jose M. Resurreccion were elected Barangay Councilmen of Barangay Dolores, Taytay, Rizal under Batas Pambansa Blg. 222.
- Section 3 of BP 222 fixed their term at six years, commencing June 7, 1982 and expiring June 7, 1988.
- Designation of Successors
- On February 8, 1987, OIC Governor Benjamin B. Esguerra signed two memoranda (antedated December 1, 1986) designating Florentino G. Magno as Captain and Remigio M. Tigas, Ricardo Z. Lacanienta, Teodoro V. Medina, Rosendo S. Paz, and Teresita L. Tolentino as Councilmen.
- Petitioners received copies on February 9, 1987. Respondent OIC Governor later averred in affidavit that he actually signed on February 8, 1987 and disseminated on February 9, 1987.
- Proceedings Below
- Petitioners filed an original action for prohibition, praying the Court to nullify the memoranda and enjoin respondents from taking over their positions.
- Respondents filed a Comment relying on Section 2, Article III of the 1986 Provisional Constitution; petitioners filed a Reply.
Issues:
- Whether the OIC Governor validly designated replacements for petitioners within the one-year transition period under the 1986 Provisional Constitution.
- Whether the ratification and effectivity of the 1987 Constitution terminated respondents’ authority to replace elective barangay officials.
- Whether the term of office fixed by BP 222 remains operative under the 1987 Constitution’s transitory provisions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)