G.R. No. 130775 - National Liga ng mga Barangay vs. Paredes

On June 11, 1997, Manuel A. Rayos, Punong Barangay of Barangay 52, Caloocan City, filed a petition before the Regional Trial Court (RTC) of Caloocan for prohibition and mandamus, alleging irregularities in the synchronized Liga ng mga Barangay elections scheduled for June 14, 1997.
The alleged irregularities included:

Publication of election notice in the Manila Bulletin without written notice to individual punong barangays of Caloocan City.
Ambiguous meeting time in the Notice of Meeting dated June 8, 1997, with the location set in Lingayen, Pangasinan, far from Caloocan.
Early deadline for filing Certificates of Candidacy, causing Rayos to miss it due to lack of necessary documents.

A temporary restraining order (TRO) was issued on June 13, 1997, enjoining the holding of the June 14 elections, but was allegedly not properly served on Alex L. David, who proceeded to hold the elections and was proclaimed President of Liga ng mga Barangay - Caloocan.
On July 17, 1997, Rayos filed a second petition for quo warranto, mandamus, and prohibition against David, Nancy Quimpo, and Secretary Robert Z. Barbers of the Department of the Interior and Local Government (DILG), asserting he was duly elected President of the Caloocan Liga Chapter.
A TRO was granted on July 18, 1997, restraining the synchronized Liga elections scheduled for July 19, 1997, limited to maintaining the status quo.

The cases were consolidated on July 18, 1997.
On July 25, 1997, the DILG Secretary Barbers filed an Urgent Motion seeking appointment as interim caretaker of the Liga ng mga Barangay to manage its affairs until duly elected officers assume office. The motion was anchored on:

The DILG’s power of general supervision over all local government units via Administrative Order No. 267 (1992).
The characterization of the Liga as a government organization.
Reports of interference by local officials in Liga elections.
Improper confirmations of elected Liga officers by David and the National Liga Board.
The need to restore order amid confusion in Liga operations.

Petitioner David opposed the motion, arguing the DILG is a party to the case and could not seek sanctions without leave, and that the appointment interfered with Liga’s internal affairs, which are not subject to DILG supervision.
Before the lower court’s action on the motion, on July 28, 1997, the DILG issued Memorandum Circular No. 97-176 directing local officials not to recognize David as Liga President or his pronouncements until further notice.

On August 4, 1997, RTC Judge Victoria Isabel A. Paredes granted the DILG’s motion, appointing it as interim caretaker of the Liga ng mga Barangay until a new set of officers are elected and assume office.
Petitioner David filed a motion for reconsideration and sought to cite Secretary Barbers in contempt for issuing the Memorandum Circular before the order was promulgated.
The DILG issued Memorandum Circular No. 97-193 on August 11, 1997, providing supplemental guidelines for synchronized Liga elections and scheduling them for August 23 (provincial and metropolitan) and September 6, 1997 (national).
On August 12, 1997, the DILG appointed Manuel A. Rayos as President of the Caloocan Liga Chapter, purportedly legitimizing his ex-officio membership in the Sangguniang Panlungsod and participation in the national elections.
The DILG conducted synchronized elections on August 23 and September 6, leading to the election of James Marty L. Lim as National Liga President.
On October 1, 1997, the RTC denied the motion for reconsideration filed by David, upholding the interim caretaker appointment and refusing to cite Secretary Barbers in contempt.
On October 10, 1997, petitioners filed a Petition for Certiorari under Rule 65 seeking to annul the RTC orders of August 4 and October 1, 1997, contesting the DILG’s authority and the appointment as interim caretaker.

The power of general supervision under Administrative Order No. 267 does not apply to the Liga as it is not a local government unit (LGU).
The incumbents of the Liga have vested rights and can only be removed for cause under the Liga’s Constitution and By-Laws.
The appointment of the DILG as interim caretaker amounted to control, not just supervision.
The DILG’s appointment of Rayos as Liga Caloocan President during the pendency of quo warranto proceedings against him was improper.
DILG’s Memorandum Circular No. 97-193 superseded and invalidated the Liga’s own guidelines.
Cited Taule v. Santos to show the Secretary of Local Government has no authority to interfere in Liga elections.

The Solicitor General sided with petitioners, stating that the DILG’s acts were acts of control, exceeding the power of supervision recognized by the Constitution, and that the Liga is not strictly an LGU.

James Marty L. Lim, elected Liga National President, filed a Comment in Intervention asserting that the case was moot and academic due to the election of new officers and the turnover of administration from the DILG to the Liga.
Another petition contesting the DILG’s authority was filed but later dismissed for lack of proof of service.
Petitioner Alex L. David died and was substituted by his legal representatives.
The consolidated petition raised the essential issue of whether the RTC acted with grave abuse of discretion in appointing the DILG as interim caretaker, implicating the nature of the Liga and the scope of the DILG’s supervisory power over it.

Whether the Liga ng mga Barangay is a government organization subject to the Department of the Interior and Local Government (DILG) Secretary’s power of general supervision over local governments as the alter ego of the President.

Whether the appointment of the DILG as interim caretaker of the Liga ng mga Barangay and the subsequent acts by the DILG, including issuance of Memorandum Circulars No. 97-176 and 97-193, constitute an exercise of supervision or control over the Liga.

Whether the Regional Trial Court committed grave abuse of discretion in appointing the DILG as interim caretaker of the Liga.

Whether the petition had become moot and academic due to the subsequent conduct of Liga elections and assumption of office by new Liga officers.