G.R. No. 76532 - Lacanilao vs. De Leon

Petitioner: Dr. Flor J. Lacanilao, asserting his lawful appointment as Chief of the Aquaculture Department of the Southeast Asian Fisheries Development Center (SEAFDEC).
Respondent: Capt. Juan de Leon (P.N.), a retired navy captain who later attempted to usurp the office.
SEAFDEC was established pursuant to an Agreement signed on December 28, 1967, by ten Southeast Asian countries, with the general purpose of promoting fisheries development in the region.
The organizational structure included the Council, the Secretariat, and various Departments, with each Department headed by a Department-Chief.

On or about early April 1986, just before and immediately after the February 1986 revolution in the Philippines, Dr. Alfredo C. Santiago, Jr. vacated the office following intense political pressure.
By a letter dated April 8, 1986, the Minister of Agriculture and Food—acting “by authority of the President”—nominated Dr. Lacanilao as Chief of the Aquaculture Department.
The nomination was communicated to the Secretary-General of SEAFDEC in Bangkok via urgent telex, where he was instructed to serve as officer-in-charge pending the Council’s formal approval.
Subsequent telex messages, dated April 11 and June 13, 1986, confirmed that a majority vote, and later a unanimous vote, had been secured by the SEAFDEC Council for Dr. Lacanilao’s appointment.
Dr. Lacanilao then assumed official duties as Department-Chief from early April 1986 until the events of November 1986.

On or about November 21, 1986, while the petitioner was abroad in Tokyo attending the SEAFDEC Council meeting, the respondent, accompanied by retainers and assistants, physically occupied the offices and facilities of the Aquaculture Department in several Philippine locations (including Manila, Binangonan, Naujan, Tigbauan, Leganes, and Iloilo).
The respondent not only took physical possession of various offices but also immediately began exercising the functions of the Department-Chief by assuming control over financial transactions, equipment assignments, and personnel matters.
Petitioner and his designated officers and employees vehemently protested the respondent’s unilateral actions.

On November 25, 1986, Dr. Lacanilao filed a sworn Petition for Quo Warranto with a prayer for a preliminary injunction in the Court, challenging the respondent’s usurpation of his office.
On November 26, 1986, an urgent ex-parte motion for a temporary restraining order (TRO) was filed, following the issuance of summons and a restraining order by the Regional Trial Court of Pasig, Branch 151, in Civil Case No. 54091 intended to halt the petitioner’s official functions.
On November 27, 1986, the Court issued a TRO enjoining Judge Migrino from proceeding with the civil case and restraining the respondent from assuming or continuing to exercise the powers and functions of the office.
In a Comment filed on December 18, 1986, the respondent justified his actions by asserting that he was nominated as Chief by a letter dated November 12, 1986, from the Vice President and Minister for Foreign Affairs, which he claimed constituted his right to the office.
However, the SEAFDEC Council, as evidenced by a letter dated November 21, 1986, refused to approve the respondent’s nomination, thereby maintaining the petitioner’s lawful appointment.

Whether Dr. Flor J. Lacanilao’s appointment as Chief of the Aquaculture Department was duly effected under the provisions of the SEAFDEC Agreement and the corresponding domestic acts, including a correct nomination by the Philippine government and approval by the SEAFDEC Council.

Whether the nomination of Capt. Juan de Leon by the Philippine government on November 12, 1986, can validly override or annul the petitioner's prior and lawful appointment.
Whether the respondent’s actions in physically occupying the offices and exercising the functions of the office, without proper confirmation by the SEAFDEC Council, are legally tenable.

Whether the Court possesses jurisdiction to entertain a quo warranto petition involving an office within an intergovernmental organization, particularly when the responsibility over nominations and removals primarily rests with the SEAFDEC Council.
Whether domestic courts may provide injunctive relief to protect the rights of a Philippine citizen holding an office within an international organization operating within Philippine territory.

Whether the appointment and removal powers vested in the SEAFDEC Council, as stipulated in Articles 6 and 10 of the Agreement, may be delegated to the Secretary-General, thereby affecting the validity of the respondent’s claims.