A.C. No. 12876 - Dillon vs. De Quiroz

Petitioner Salvio B. Fortuno and respondent Joel David S. Abante were candidates for the position of director representing District V of the Camarines Sur II Electric Cooperative, Inc. (CASURECO II).
Abante, having also been a candidate, raised questions about the qualification of Fortuno based on his alleged non-residence in the area covered by District V as mandated by the cooperative’s by-laws.
The case arose from internal disputes regarding the election process governed by the Electric Cooperative Election Code and the supervisory authority of the National Electrification Administration (NEA).

On January 30, 1985, Abante filed a petition with the NEA seeking Fortuno’s disqualification on the ground of non-residence.
The NEA directed the CASURECO II Board of Directors to act per the by-laws and the Election Code, and the petition was subsequently endorsed to the District Election Committee (DEC).
On February 4, 1985, Abante sent another letter to the DEC reiterating his complaint regarding Fortuno’s residency status.

The DEC, as mandated to settle all electoral matters including protests and disqualification petitions, held a hearing on February 8, 1985, wherein Fortuno submitted his comment within the prescribed 48 hours.
The DEC ruled in Resolution No. 04, dated February 8, 1985, denying Abante’s petition and confirming that Fortuno was a resident within District V.
On February 9, 1985, the election was conducted; Fortuno garnered 1,429 votes against Abante’s 637 votes, and the DEC officially proclaimed Fortuno as the duly elected director for District V.

On February 18, 1985, Abante initiated a quo warranto petition in the Regional Trial Court (RTC) of Naga City (Case No. RTC‑85‑607) with a prayer for a preliminary injunction and temporary restraining order against Fortuno and CASURECO II.
At the preliminary injunction hearing, Fortuno and other respondents raised the issue of the RTC’s jurisdiction over a matter that ostensibly fell under the purview of the NEA and the DEC.
On March 13, 1985, the RTC issued an order upholding its jurisdiction over the case; a subsequent motion for reconsideration was denied on March 16, 1985.
On March 18, 1985, the RTC reset the hearing for the preliminary injunction to March 25, 1985 and simultaneously issued a restraining order preventing Fortuno from assuming or performing the functions of a Board member until further orders.
On March 19, 1985, a supplemental petition was filed by the petitioners, highlighting the restraining order’s effect on Fortuno’s impending assumption of office (with his term ending on March 30, 1985) and requesting that further proceedings be halted.
The respondents filed their comments by March 25, 1985, and after due course, on October 9, 1985, the RTC gave due course to the petition, with only petitioners submitting their simultaneous memoranda.

Petitioners contended that the NEC’s supervisory power and the internal election rules granted to the DEC rendered its decision final and that the RTC therefore lacked jurisdiction over a matter that had already been settled administratively.
They argued that the decision of the DEC, which upheld Fortuno’s qualification based on residency and was unchallenged within the reglementary period, should bar further judicial intervention.
Citing statutory provisions and previous rulings, petitioners maintained that the RTC could not override the DEC’s final determination, thus questioning the appropriateness of a quo warranto proceeding in this context.

Whether the RTC has jurisdiction to hear a quo warranto proceeding challenging the qualification of a director of an electric cooperative, given that the election dispute was already decided by the DEC under NEA supervision.
Whether the decision of the DEC, as the designated body for handling electoral disputes under the Electric Cooperative Election Code, is immune from judicial review.

Whether the failure of Abante to appeal the DEC’s resolution within the prescribed 72‑hour period constitutes an absolute bar to the quo warranto suit.
Whether judicial intervention is justified despite the availability of the administrative appeal process provided by the NEA and the DEC.

Whether the controversy concerning the qualification of Fortuno—specifically the alleged non-residence issue—presents a justiciable matter for the courts, despite allegations of arbitrariness in the DEC’s decision.
Whether internal affairs of a corporation under NEA supervision fall exclusively within the purview of administrative bodies or if judicial review is warranted in cases of abuse of discretion.