Case Digest (G.R. No. 154599)
Facts:
The Liga ng mga Barangay National, petitioner, v. The City Mayor of Manila, Hon. Jose Atienza, Jr., and the City Council of Manila, G.R. No. 154599, January 21, 2004, the Supreme Court En Banc, Davide Jr., C.J., writing for the Court.Petitioner Liga ng mga Barangay National (the Liga) is the national organization of barangay officials created under Republic Act No. 7160 (the Local Government Code of 1991). Pursuant to the Liga’s adopted Constitution and By‑Laws (ratified 16 March 2000) and its Election Code, the Liga scheduled synchronized chapter elections nationwide and set 21 October 2002 for highly urbanized city (HUC) chapters, including Manila’s City Chapter.
On 28 June 2002 the City Council of Manila enacted Ordinance No. 8039, Series of 2002, prescribing procedures for election of Liga officers in Manila’s district and city chapters and providing that district chapter elections be held thirty days after the barangay elections. The ordinance provided that barangays be represented by their Punong Barangay (or a kagawad in certain cases), that Barangay Chairmen in each district elect among themselves district officers, and that district representatives then compose the city board and elect city officers. The ordinance was transmitted to City Mayor Jose L. Atienza, Jr., who, despite a July 16, 2002 letter from the Liga requesting a veto, signed the ordinance and on 15 August 2002 issued Executive Order No. 011, Series of 2002 to implement it.
On 27 August 2002 the Liga filed a petition for certiorari under Rule 65 of the Rules of Court seeking nullification of Ordinance No. 8039 and Executive Order No. 011 as ultra vires and contrary to law; it also prayed for a temporary restraining order. On 12 September 2002 Barangay Chairman Arnel Pena intervened, echoing the Liga’s claims and arguing that the ordinance unlawfully substituted the at‑large election scheme for an indirect election among district chairmen, thereby impairing members’ rights to vote and to be voted upon. The Office of the Solicitor General filed a manifestation supporting the Liga and asked this Court to relax the hierarchy‑of‑courts rule in light of exigent circumstances. Respondents opposed the petition on multiple grounds: that certiorari under Rule 65 was inapplicable because the City Council and Mayor exercised legislative and executive functions (not judicial or quasi‑judicial), that other actions challenging the ordinance were pending in the Regional Trial Court and Court of Appeals (raising forum‑shopping and availability of adequate remedies), and that the challenged acts were already a fait accompli because Liga officers had been elected on 15 September 2002.
After considering the...(Pro-only)
Issues:
- Is a petition for certiorari under Rule 65 the proper remedy against the City Council of Manila and City Mayor for enactment and implementation of Ordinance No. 8039 and Executive Order No. 011 (i.e., did respondents act in a judicial or quasi‑judicial capacity)?
- May this Court exercise original jurisdiction to decide the legality or constitutionality of the ordinance and executive order as a petition for declaratory relief, or must such relief be sought in the lower courts?
- Were there special and important reasons that excused the petitioner’s failure to observe the hierarchy of courts and permitted direct invocation of this Court’s original jurisdiction in the circumstances of this case?
- (Procedural) Did the petition amount to forum‑shopping or present mo...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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