G.R. No. 80391 - Limbona vs. Mangelin

On September 24, 1986, Sultan Alimbusar P. Limbona (petitioner) was appointed member of the Sangguniang Pampook, Regional Autonomous Government, Region XII, representing Lanao del Sur.
On March 12, 1987, petitioner was elected Speaker of the Regional Legislative Assembly (Batasang Pampook) of Region XII, composed of eighteen members.

Respondents Acmad Tomawis and Rakil Dagalangit filed certificates of candidacy on March 23, 1987 for the May 11, 1987 congressional elections; they later withdrew and resumed their Assembly seats.
No formal vacancy or replacement proceedings appear in the Assembly records concerning these members.

On October 21, 1987, Congressman Datu Guimid Matalam, Chairman of the House Committee on Muslim Affairs, invited the petitioner and other regional legislators to congressional consultations from November 1–15, 1987.
Petitioner instructed Acting Secretary Johnny Alimbuyao by telegram to inform all Pampook Assemblymen that there would be no session in November, as attendance at the House committee hearings “takes precedence over any pending business in Batasang Pampook.”
Acting Secretary Alimbuyao relayed the telegram verbatim to assembly members.

On November 2, 1987, ten assemblymen convened despite the recess order, declared a quorum, authorized the Speaker Pro Tempore to preside, and voted unanimously to declare the Speaker’s seat vacant.
On November 5, 1987, fourteen assemblymen (including some not present earlier) reconvened, confirmed the November 2 proceedings, and by twelve affirmative votes (one abstention) again declared the Speaker’s seat vacant.

Preliminary injunction against further sessions by respondents.
Declaration that the November 2 and 5 proceedings were null and void.
Recognition of petitioner’s March 12, 1987 election as Speaker as valid and subsisting.

On January 19, 1988, while the petition was pending, the Assembly adopted a resolution expelling the petitioner on grounds of unauthorized salary disbursements, usurpation of Assembly powers, and filing a Supreme Court case against members.

Presidential Decree No. 1618 (July 25, 1979) created “internal autonomy” for Regions IX and XII, subject to the national Constitution, and vested the President with general supervision and control over autonomous regions.
The Decree defined the Sangguniang Pampook’s powers primarily as administrative and legislative within the framework of national policies, and maintained liaison with the Batasang Pambansa.

Whether the Assembly’s expulsion of petitioner pending litigation rendered the Supreme Court petition moot and academic.
Whether acts of the autonomous Sangguniang Pampook of Region XII fall within the jurisdiction of the national courts.
Whether the November 2 and 5, 1987 sessions and the consequent ouster of the Speaker were valid under the Region XII Sanggunian Rules on recess and session.
Whether the ouster of the petitioner as Speaker was effective for lack of quorum.