G.R. No. 187256 - Mendoza vs. Villas

Constancio F. Mendoza obtained the highest number of votes for the position of Punong Barangay of Barangay Balatasan, Bulalacao, Oriental Mindoro.
Liwanag Herato, a Barangay Kagawad, emerged with the highest votes for that position.

Concurrently, Mayor Enrilo Villas was the incumbent mayor of Bulalacao, Oriental Mindoro, involved in the political dynamics of the election.

The Commission on Elections (COMELEC) proclaimed Mendoza as the duly-elected Punong Barangay of Balatasan.
Thomas Pajanel, the losing candidate, filed a petition for quo warranto with the Municipal Trial Court (MTC) of Mansalay-Bulalacao, docketed as Election Case No. 407-B.
The MTC issued a Decision dated February 23, 2008, disqualifying Mendoza and declaring that Herato was entitled to the position, as he garnered the highest number of votes as a Barangay Kagawad.
Mendoza appealed the MTC Decision to COMELEC, while on February 28, 2008, Mayor Villas administered the Oath of Office to Herato.

Mayor Villas issued Memorandum No. 2008-03-010 (March 3, 2008), directing municipal department heads to act only on documents signed or authorized by Herato.

Mendoza sought clarification from the Department of the Interior and Local Government (DILG) regarding who should exercise the powers of Punong Barangay given the controversy.

On April 11, 2008, DILG Undersecretary Austere A. Panadero advised Mendoza that, since there was no Writ of Execution Pending Appeal of the MTC Decision, Mendoza should occupy the post.

However, the Bulalacao Municipal Administrator, Edezer Aceron, acting under Mayor Villas’ authority, issued a letter on April 23, 2008, to Marlon de Castro (Manager, Pinamalayan Branch, Land Bank of the Philippines) instructing that transactions entered on behalf of Mendoza be disallowed.

In response, on April 24, 2008, de Castro communicated to both Villas and Mendoza that the Land Bank would not honor any transactions related to the accounts of Barangay Balatasan.

Petitioners (Mendoza and the Sangguniang Barangay of Balatasan) filed a Petition for Mandamus with Damages and for a Writ of Preliminary Mandatory Injunction on May 5, 2008 (docketed as Special Civil Action No. 08-10).

The petition sought to direct the Land Bank of the Philippines to release the barangay funds so that basic public services could be rendered.

Respondents (Mayor Villas, Barangay Kagawad Herato, and Marlon de Castro) answered:

They raised affirmative defenses arguing that the petition was defective—directed against two or more different entities and requiring the performance of disparate acts.
They also contended that Mendoza lacked a clear and legal right to the writ of mandamus.

The Land Bank of the Philippines, in its Answer dated June 5, 2008, maintained that its withholding of the barangay funds was an act of prudence amid the controversy and declared its readiness to release the funds upon proper direction from the Court.

On November 7, 2008, Villas and Herato filed a Motion to Dismiss, attaching the COMELEC Resolution dated September 8, 2008 (from COMELEC Case No. SPA-07-243-BRGY) which disqualified Mendoza on the ground that he had already served three consecutive terms.
In response, Mendoza submitted a COMELEC Certification on February 27, 2009, asserting that the disqualification case was still pending.
Mendoza further sought the opinion of the DILG, resulting in DILG Opinion No. 5, Series of 2009 (issued January 2009), reiterating that the MTC Decision had not become final and executory.
The Regional Trial Court (RTC) ultimately issued an Order on February 2, 2009, dismissing the petition on the basis of the pending and adverse COMELEC Resolution.
A subsequent motion for reconsideration was filed by the petitioners but was denied on March 17, 2009.
Petitioners then directly resorted to the Supreme Court, resulting in the present petition, raising issues about filing under Rule 65 versus Rule 45 and the appropriate forum for addressing only questions of law.

Whether the petition, despite not citing a specific rule, should be treated as filed under Rule 45 (appeal on questions of law) rather than Rule 65.
Whether the petitioners’ direct recourse to the Supreme Court is justified given the established hierarchy and the principle that petitions should first be filed with the appropriate lower courts.

Whether the issues raised remain justiciable considering that Mendoza’s term of office had expired after the 2010 barangay elections.
Whether the supervening event (the local elections that rendered Mendoza’s interest academic) amounts to a moot case unsuitable for further adjudication.

Whether the petition suffers from serious procedural defects that would preclude the Supreme Court from reviewing the factual findings of lower courts.
Whether the absence of special and important reasons to bypass the ordinary appellate channels invalidates the petition for direct recourse.