Case Digest (G.R. No. 130775)
Facts:
National Liga ng mga Barangay, represented by Alex L. David, et al., G.R. Nos. 130775 and 131939, September 27, 2004, the Supreme Court En Banc, Tinga, J., writing for the Court. The petitions challenged the appointment of the Department of the Interior and Local Government (DILG) as interim caretaker of the Liga ng mga Barangay and related DILG issuances.On June 11, 1997 Manuel A. Rayos filed a petition (SCA No. C-508) before the Regional Trial Court (RTC), Branch 124, Caloocan, alleging irregularities in the notice, venue and conduct of the scheduled synchronized Liga elections in Caloocan; an Executive Judge issued a 72-hour temporary restraining order (TRO). Despite alleged defective service of the TRO, the City chapter proceeded with elections on June 14, 1997, and Alex L. David was proclaimed president and assumed ex-officio membership in the Sangguniang Panlungsod.
Rayos then filed another action (SCA No. C-512, Branch 126) on July 17, 1997, claiming he had been elected Liga-Calocan president and seeking quo warranto, mandamus and prohibition; the presiding judge granted a limited TRO on July 18, 1997. The two special civil actions were consolidated on July 18, 1997. On July 25, 1997 the DILG, through Secretary Robert Z. Barbers, filed an Urgent Motion in the consolidated proceedings requesting that the DILG be appointed as interim caretaker to “manage and administer the affairs of the Liga” pending proper elections; the DILG invoked Administrative Order No. 267 (1992) as a basis for the President’s power of general supervision.
Before the RTC acted, the DILG issued Memorandum Circular No. 97-176 (July 28, 1997) directing local officials not to recognize David and to disregard his pronouncements. On August 4, 1997, Judge Victoria Isabel A. Paredes granted the DILG’s motion and appointed the DILG interim caretaker of the National Liga Board. David moved for reconsideration and sought contempt proceedings against Secretary Barbers. The DILG thereafter issued Memorandum Circular No. 97-193 (Aug. 11, 1997) setting supplemental election guidelines and schedules, and on August 12, 1997 it issued a Certificate of Appointment naming Rayos as Liga-Caloocan president.
The DILG conducted synchronized provincial and metropolitan elections on August 23, 1997 and the National Chapter election on September 6, 1997, resulting in the election of James Marty L. Lim as National Liga President. The RTC denied reconsideration on October 1, 1997. Petitioners filed a petition for certiorari under Rule 65 on October 10, 1997 seeking to annul the RTC’s August 4 and October 1 orders. Intervenor Lim moved to dismiss as moot after the DILG-conducted elections; the Solicitor General filed a position siding with petitioners that the DILG had exceeded supervisory powers. Another related petition (G.R. No. 131939) was consolidated but late...(Pro-only)
Issues:
- Is the petition moot because subsequent Liga elections occurred and the DILG purportedly turned over management to newly elected officers?
- Is the Liga ng mga Barangay a government organization subject to the President’s power of general supervision exercised through the DILG (Art. X, Sec. 4, 1987 Constitution)?
- Did the RTC act with grave abuse of discretion in appointing the DILG as interim caretaker and did DILG Memorandum Circulars Nos. 97-176 and 97-193 and attendant acts co...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)