Case Digest (G.R. No. 221153) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 103702, decided on December 6, 1994, the Municipality of San Narciso, Quezon, with Mayor Juan K. Uy and its municipal councilors as petitioners, assailed the creation of the Municipal District of San Andres by Executive Order No. 353 dated August 20, 1959, issued by President Carlos P. Garcia. The order had carved out the barrios of San Andres, Mangero, Alibijaban, Pansoy, Camflora and Tala from San Narciso. By Executive Order No. 174 of October 5, 1965, President Diosdado Macapagal recognized the district as a fifth class municipality effective July 1, 1963, under Republic Act No. 1515. On June 5, 1989, San Narciso filed a quo warranto petition in RTC Branch 62, Gumaca, Quezon, seeking nullity of EO 353 and enjoining San Andres officials from office. Respondents raised defenses of estoppel, corporate personality, and improper party, while also invoking Republic Act No. 7160 (Local Government Code of 1991), Section 442(d) which deemed existing municipal districts as Case Digest (G.R. No. 221153) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Creation of the Municipal District of San Andres
- On 20 August 1959, President Carlos P. Garcia issued Executive Order No. 353, segregating the barrios of San Andres, Mangero, Alibijaban, Pansoy, Camflora and Tala (with their sitios) from the Municipality of San Narciso, Quezon, thereby creating the municipal district of San Andres.
- EO No. 353 was adopted upon request of the San Narciso municipal council through Resolution No. 8 dated 24 May 1959, approved by the Provincial Board of Quezon.
- Recognition as a Fifth Class Municipality
- By Executive Order No. 174 dated 5 October 1965, President Diosdado Macapagal officially recognized San Andres as a fifth class municipality, effective 1 July 1963, pursuant to the income requirements of Republic Act No. 1515.
- The EO acknowledged congressional approval under House Bill No. 4864.
- Quo Warranto Proceedings in RTC
- On 5 June 1989, the Municipality of San Narciso filed Special Civil Action No. 2014-G for quo warranto before RTC Branch 62 (Gumaca, Quezon), seeking nullification of EO No. 353 and enjoining San Andres officials from exercising their functions.
- Defenses of respondents included estoppel, corporate personality by long existence, and improper party (quo warranto being a prerogative of the State).
- Lower Court Dispositions
- On 27 November 1991, San Andres moved to dismiss as moot and academic, invoking Section 442(d) of the Local Government Code of 1991 (“all existing municipal districts organized pursuant to executive orders shall henceforth be considered as regular municipalities”).
- RTC Branch 62 on 2 December 1991 dismissed the petition for lack of cause of action and held that R.A. 7160 cured any defects; motion for reconsideration was denied on 17 January 1992.
- Appeal to the Supreme Court
- Petitioners argued grave abuse of discretion, lack/excess of jurisdiction, and unconstitutionality of EO No. 353 as an impermissible delegation of legislative power.
- Respondents and amici pointed to long acquiescence, de facto status, congressional and administrative recognition, and the curative effect of Section 442(d), R.A. 7160.
Issues:
- Whether Executive Order No. 353 was an unconstitutional usurpation of legislative power and void ab initio.
- Whether the Municipality of San Narciso had a timely and proper cause of action to question the existence of San Andres after thirty years.
- Whether Section 442(d) of the Local Government Code of 1991 validly cured any defects in the creation of San Andres and conferred de jure municipal status.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)