Case Digest (G.R. No. L-23967)
Facts:
The case involves Antonino M. Milanes, the petitioner, who served as the municipal mayor of Agoo, La Union. On February 9, 1962, he filed a petition against Eulogio F. de Guzman, the Provincial Governor of La Union, along with the Vice-Governor and members of the Provincial Board of La Union, in the Court of First Instance of La Union. The petition arose after the Governor suspended Milanes from office on February 8, 1962, based on an administrative complaint filed by Rolando Rivera. The complaint accused Milanes of slander and serious threats made during a political rally on November 13, 1961. The criminal cases initiated by Rivera against Milanes were still pending in the Justice of the Peace Court of Agoo at the time of the suspension. Milanes contended that the Governor acted beyond his jurisdiction and with grave abuse of discretion, as the allegations did not warrant suspension under Section 2188 of the Revised Administrative Code. He sought a writ of preliminary injunc...
Case Digest (G.R. No. L-23967)
Facts:
- Petitioner's Position and Suspension: Antonino M. Milanes, the municipal mayor of Agoo, La Union, was temporarily suspended from office on February 8, 1962, by Provincial Governor Eulogio F. de Guzman. The suspension was based on an administrative complaint filed by Rolando Rivera, who accused Milanes of slander by word, slander by deed, and serious threats during a political rally on November 13, 1961.
- Criminal Cases: Rivera also filed criminal cases against Milanes in the Justice of the Peace Court of Agoo, which were still pending at the time of the suspension.
- Petitioner's Allegations: Milanes claimed that the Governor acted in excess of jurisdiction and with grave abuse of discretion in suspending him. He sought a writ of preliminary injunction to restrain the Governor from enforcing the suspension and later amended his petition to include the Vice-Governor and Members of the Provincial Board of La Union as respondents.
- Dismissal of Criminal Cases: The criminal cases filed by Rivera were dismissed by the Justice of the Peace Court of Agoo.
- Administrative Complaint: Milanes argued that the allegations in the administrative complaint did not warrant his suspension and did not fall under the grounds specified in Section 2188 of the Revised Administrative Code for disciplinary action against municipal officers.
- Lower Court's Decision: The Court of First Instance of La Union granted Milanes' petition, issuing writs of preliminary mandatory injunction and preliminary injunction. The court later made these writs permanent, ruling in favor of Milanes.
- Appeal and Certification: Respondents appealed to the Court of Appeals, which certified the case to the Supreme Court, as it involved only questions of law.
Issue:
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Ruling:
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Ratio:
- Scope of Section 2188: Section 2188 of the Revised Administrative Code provides grounds for disciplinary action against municipal officers, including neglect of duty, oppression, corruption, or other forms of maladministration of office, and conviction by final judgment of a crime involving moral turpitude.
- Private vs. Official Acts: The Court emphasized that not all acts performed by a mayor during their tenure are official. The acts in question occurred during a political rally, where Milanes acted in his private capacity as a toastmaster, not in connection with his official duties as mayor.
- Misconduct in Office: The Court found that Milanes' actions, while inappropriate, did not amount to oppression, abuse of authority, or misconduct in office. His behavior was prompted by personal affronts and did not involve the use of his official powers.
- Precedent: The Court cited previous cases (Lacson vs. Roque, Mondano vs. Silvosa, and Cornejo vs. Naval) to support the distinction between private misconduct and official misconduct. Acts committed in a private capacity, even if morally reprehensible, do not constitute grounds for administrative action unless they are directly connected to the performance of official duties.
- Mootness: The Court noted that the case had become moot since Milanes' term as mayor had already expired by the time the case reached the Supreme Court. However, it proceeded to rule on the merits to provide guidance on the legal issues involved.