G.R. No. 154599 - Liga ng mga Barangay National vs. City Mayor of Manila

Petitioner: Liga ng mga Barangay National, the national organization of all barangays in the Philippines, composed of duly elected officers as provided under Section 492 and Section 493 of Republic Act No. 7160 (Local Government Code of 1991).
Respondents:

The Liga’s constitutional and by-law framework was established on 16 March 2000, governing its internal organization and elections.
Adoption of the Liga Election Code pursuant to the Liga Constitution, which provided a standardized procedure for the synchronized elections of its various chapters (including highly urbanized city chapters such as the Manila Chapter).
The Liga's Calendar of Activities and Guidelines under the Liga Election Code set synchronized elections for the highly urbanized city chapters on 21 October 2002.

On 28 June 2002, the Manila City Council enacted Ordinance No. 8039, Series of 2002, which:

Provided for the election of representatives of the District Chapters in the City Chapter of Manila.
Prescribed that elections for both the District and City Chapters should take place thirty days after the barangay elections.

On 15 August 2002, subsequent to the ordinance’s enactment and notwithstanding a prior request by the Liga for veto, the City Mayor approved the ordinance by issuing Executive Order No. 011, Series of 2002.

Contradicted the Liga Election Code, which governs the conduct of elections for its officers and chapters.
Encroached upon the internal functions of the Liga by assuming legislative prerogatives not vested in local government units.

Petition for certiorari was filed on 27 August 2002 seeking to annul the aforesaid ordinance and executive order as ultra vires.

The petition argued that the City Council and City Mayor acted without legal authority, thereby violating the rights of the barangay officials to vote directly in a manner consistent with the law.

A Complaint in Intervention was also filed by Barangay Chairman Arnel PeAa on 12 September 2002, supporting the Liga’s position and seeking a temporary restraining order and/or preliminary injunction to forestall the implementation of the disputed measures.

The Office of the Solicitor General filed a Manifestation in lieu of Comment on 25 October 2002, supporting the petition.
The petition raised additional concerns regarding the non-observance of the hierarchy-of-courts rule and alleged forum shopping, which were later addressed in the decision.

Whether the City Council of Manila committed grave abuse of discretion or acted without/in excess of its jurisdiction by enacting Ordinance No. 8039, Series of 2002, in violation of the Liga’s Constitution, by-laws, and Election Code.

Whether the ordinance, by prescribing an election procedure differing from that provided under the Liga’s internal rules, overstepped the bounds of the City Council’s legislative power.

Whether the City Mayor of Manila committed grave abuse of discretion or acted without/in excess of his jurisdiction in issuing Executive Order No. 011, Series of 2002, to implement the questioned ordinance.

Whether such issuance unlawfully assumed functions that were reserved for the Liga and thereby contravened existing laws governing election procedures.