G.R. No. 168203 - National Electrification Administration vs. Villanueva

The case involves a petition for review on certiorari under Rule 45 filed by the National Electrification Administration (NEA) against the Decision (dated November 12, 2004) and the Resolution (dated April 6, 2005) of the Regional Trial Court (RTC) of Cabadbaran, Agusan del Norte, Branch 34 in SP. Civil Case No. 03-03.
The RTC’s decision pertained to issues involving the qualification of Val L. Villanueva as a member of the Board of Directors (BOD) of the Agusan del Norte Electric Cooperative (ANECO).

Elected member of the ANECO BOD for a term originally scheduled for 2001–2003, later extended until 2006 due to redistricting.
In 2002, while still serving on the ANECO board, he was elected as Barangay Chairman of Barangay 12 in Cabadbaran and subsequently as President of the Liga ng mga Barangay (formerly Association of Barangay Captains) of the municipality.
By virtue of his position as Liga President, Villanueva assumed an ex-officio role as a member of the Sangguniang Bayan of Cabadbaran.

The NEA became involved after its General Manager sought its opinion regarding Villanueva’s continued eligibility for the ANECO BOD.
The NEA Director for Co-Op Operations issued an opinion on December 10, 2002, asserting that Villanueva was automatically disqualified (or had resigned) upon taking his oath as Liga President.

The NEA Director based the disqualification opinion on provisions of the Local Government Code of 1991, an NEA Memorandum dated February 13, 1998, and the Guidelines in the Conduct of Electric Cooperative District Elections.
Villanueva, seeking clarity, wrote on January 3, 2003, to the Provincial Director of the Department of Interior and Local Government (DILG).
On January 7, 2003, the DILG Provincial Director expressed that while his office could not formally opine (given the jurisdiction of another agency), it was his view that Villanueva was only an ex-officio member of the Sangguniang Bayan, not a regularly elected one.

On January 31, 2003, Villanueva requested a review of the NEA’s disqualification opinion.
This request was denied on February 17, 2003, by the NEA Chief Operating Officer/Deputy Administrator for Co-Op Development.

Villanueva, aggrieved by the denial of review, filed a petition for certiorari with a prayer for a preliminary injunction against NEA and ANECO.
On December 2, 2003, the RTC issued a Temporary Restraining Order (TRO) enjoining NEA and ANECO from effectively disqualifying him from the ANECO BOD and directing them to restore his benefits.

NEA and ANECO filed separate motions for reconsideration.
The RTC, on January 7, 2004, denied these motions, ordered the issuance of a preliminary injunction, and required a bond of ₱300,000.00.
A Writ of Preliminary Injunction was issued on February 10, 2004.

On November 12, 2004, the RTC rendered its decision granting the petition and making the TRO permanent, while also ordering NEA and ANECO to pay ₱50,000.00 each in attorney’s fees and litigation expenses.
NEA’s subsequent motion for reconsideration was denied via a Resolution dated April 6, 2005.

Whether Hon. Orlando F. Doyon, in his capacity as Presiding Judge of the RTC, committed grave abuse of discretion by nullifying the administrative order issued by the NEA based on insufficient legal basis.

Whether Villanueva’s petition should be dismissed due to his failure to exhaust available administrative remedies, specifically his neglect to appeal the NEA’s decision to the Office of the President which supervises the NEA pursuant to Section 13, Chapter II of PD No. 269.

Whether the RTC correctly applied the Rules of Court in issuing the TRO and if its validity stands even though it was noted to have been applied for a period beyond the prescribed twenty (20) days.