Case Digest (A.M. No. 13-04-03-SC, 13-05-08-SC, 13-06-11-SC)
Facts:
- The case involves the Integrated Bar of the Philippines (IBP) and leadership disputes regarding officer nominations and elections.
- Key parties include Atty. Lynda Chaguile (IBP Ifugao Chapter President) and Atty. Marlou B. Ubano (IBP Governor for Western Visayas).
- Atty. Denis B. Habawel, IBP Governor for Northern Luzon, filed a Certificate of Candidacy for Provincial Governor of Ifugao, triggering an ipso facto resignation under IBP By-Laws.
- On March 21, 2013, the IBP Board of Governors nominated Atty. Chaguile as Habawel's replacement, despite objections from Atty. Ubano and others.
- Atty. Ubano filed a motion on March 27, 2013, claiming the nomination was ultra vires, asserting there was no vacancy and that delegates should elect a successor.
- The Supreme Court treated this motion as a separate administrative matter (A.M. No. 13-04-03-SC).
- Atty. Ubano also sought to nullify the May 22, 2013 election for IBP Executive Vice President (EVP), alleging irregularities and invalidating Atty. Chaguile's vote.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that Atty. Lynda Chaguile's designation as IBP Governor for Northern Luzon was invalid and illegal, violating the IBP By-Laws.
- The Court recognized Atty. Chaguile as a de facto officer, validating her actions, including her vote in the EVP election.
- The Cou...(Unlock)
Ratio:
- The Supreme Court emphasized that the IBP By-Laws grant the right to elect a successor to the delegates of the concerned region, not the Board of Governors.
- The Court rejected the Board's reliance on tradition, stating that such practices cannot override explicit By-Law provisions.
- Atty. Chaguile's designation was void ab initio, lacking n...continue reading
Case Digest (A.M. No. 13-04-03-SC, 13-05-08-SC, 13-06-11-SC)
Facts:
The case involves the Integrated Bar of the Philippines (IBP) and centers around the leadership controversies that arose from the nomination and election of officers within the organization. The primary parties involved are Atty. Lynda Chaguile, the IBP Ifugao Chapter President, and Atty. Marlou B. Ubano, the IBP Governor for Western Visayas. The events leading to the case began when Atty. Denis B. Habawel, the IBP Governor for Northern Luzon, filed a Certificate of Candidacy for the position of Provincial Governor of Ifugao on or before October 5, 2012. This action triggered an ipso facto resignation under the amended IBP By-Laws, which stipulates that any official who files for an elective public office is considered resigned from their position effective from the start of the official campaign period.
On March 21, 2013, the IBP Board of Governors approved the nomination of Atty. Chaguile as Habawel's replacement, despite objections from Atty. Ubano and other governors. Ubano filed a motion on March 27, 2013, seeking to declare this nomination ultra vires, arguing that there was no vacancy at the time of the nomination and that the right to elect a successor belonged to the delegates of the concerned region, not the Board of Governors. The Supreme Court treated this motion as a separate administrative matter, re-docketing it as A.M. No. 13-04-03-SC.
In a related matter, Atty. Ubano also sought to nullify the May 22, 2013 election for the IBP Executive Vice President (EVP), claiming it was marred by irregularities and that Atty. Chaguile's vote in favor of Atty. Vicente M. Joyas was invalid due to her alleged improper appointment. The Supreme Court ...