G.R. No. 221220 - Metropolitan Bank and Trust Co. vs. Cruz

On December 11, 2007, synchronized elections were held for the Liga ng mga Barangay officers and members in various municipalities and component cities.
Prior to the actual elections, the Punong Barangays of Bagac, Bataan, held an election meeting for selecting officers and members of the Board of Directors of the Liga Municipal Chapter of Bagac (Liga-Bagac Chapter).
The meeting was attended by the Punong Barangays from all 14 barangays in Bagac, including respondent Eva T. Shaikh and Ernesto N. Labog.
During the meeting, Labog, along with five other Punong Barangays and Oscar M. Ragindin (Municipal Local Government Operations Officer and BES Chairperson), walked out, leaving behind eight Punong Barangays.
The remaining eight Punong Barangays proceeded with the election, electing Shaikh as President of the Liga-Bagac Chapter.
James Marty L. Lim, the National President of the Liga, subsequently issued a Certificate of Confirmation in favor of Shaikh dated December 27, 2007.

On December 11, 2007, Oscar M. Ragindin informed the DILG-Bataan that the scheduled election did not materialize as planned.
On December 18, 2007, Ragindin issued a Certification naming Labog as Acting President, based on Lim’s earlier appointment.
The Office of the Sangguniang Bayan of Bagac requested an official endorsement from the Liga on January 9, 2008, regarding who should represent the Liga in the Sanggunian.
On the same day, the Liga, via its Director of Legal Affairs, verified Shaikh’s position as the duly elected President and ex-officio member.
Subsequent instructions by Vice-Mayor Romeo T. Teopengco on January 28 and February 26, 2008, directed Shaikh to submit required certificates for her recognition as ex-officio member.
Shaikh’s failure to provide the Certificate of Canvass and Proclamation led to further confusion regarding her entitlement and status.

Despite the controversy over the rightful holder of the Liga-Bagac Chapter presidency, Shaikh continued to attend the sessions of the Sangguniang Bayan.
Shaikh requested the release of salaries and allowances for her services from January 15, 2008 to March 31, 2008 in connection with her acting as an ex-officio member.
Vice-Mayor Teopengco forwarded her documents to the Municipal Budget Officer, Mrs. Angelina M. Bontuyan.
Mayor Rommel V. Del Rosario, in a letter dated April 14, 2008, declined her request, citing Labog’s opposing claim to the position.
Messages and letters exchanged subsequently (including one on April 17, 2008) indicated that the municipal authorities would not release the salaries until the rightful holder of the office was determined.

On March 4, 2009, Shaikh filed a Petition for Mandamus seeking an order compelling Mayor Del Rosario and Vice-Mayor Teopengco to release her due salaries and emoluments.
Shaikh also prayed that the Municipal Budget Officer be ordered to accept the pertinent documents submitted in connection with her official functions.

On November 4, 2009, the RTC dismissed Shaikh’s petition on the ground that there was a failure of elections during the December 11, 2007 meeting, and consequently, she was never lawfully elected.
The RTC reasoned that without being elected, Shaikh neither acquired de jure nor de facto rights to the office.

On September 7, 2012, the CA reversed the RTC’s decision by ruling that Shaikh, as a de facto officer who attended sessions, was entitled to her salaries and other benefits.
The CA held that in the absence of a de jure officer, municipal officials had a ministerial duty to release the payments.
On March 6, 2013, the CA denied motions for reconsideration filed by Mayor Del Rosario, Vice-Mayor Teopengco, and Budget Officer Bontuyan.

Unconvinced by the CA’s ruling, Mayor Del Rosario filed a Petition for Review on Certiorari with the Supreme Court.
A critical issue arose regarding the substitution of parties, as Vice-Mayor Teopengco had already ceased to hold office after the May 2010 elections, and Bontuyan had retired in April 2011.
The failure to make proper substitution pursuant to the relevant Rules of Court became a central point in questioning the jurisdiction and propriety of the CA’s decision against these individuals.

Whether the Court of Appeals erred in issuing a writ of mandamus compelling the release of salaries and benefits to Shaikh by directing the Municipal Mayor, Vice-Mayor, and Budget Officer.

Does the Municipal Mayor have a clear legal duty to order the release of the salaries and emoluments claimed by Shaikh?
Whether the absence of proper substitution of parties (given that Vice-Mayor Teopengco and Budget Officer Bontuyan were no longer in office) renders the CA’s decision procedurally defective.
Whether mandamus is available as an extraordinary remedy when the act to be compelled is not a ministerial duty of the official addressed—in this case, the Municipal Mayor versus the Vice-Mayor.