Title
Salva vs. Makalintal
Case
G.R. No. 132603
Decision Date
Sep 18, 2000
Residents challenged COMELEC resolution and local ordinances abolishing their barangay; Supreme Court ruled RTC had jurisdiction, resolving ministerial acts, maintaining status quo, deferring plebiscite results.

Case Digest (G.R. No. 132603)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Petitioner Group
1.1. Officials and residents of Barangay San Rafael, Calaca, Batangas, among numerous individuals, filed a class suit. 1.2. The suit sought the annulment of local legislative measures and a COMELEC resolution affecting their barangay.
  • Legislative and Administrative Acts
2.1. Ordinance No. 05 (enacted June 23, 1997) declared the abolition of Barangay San Rafael and provided for its merger with Barangay Dacanlao, Calaca. 2.2. Resolution No. 345 (dated August 4, 1997) affirmed the effectivity of Ordinance No. 05 by overriding the veto exercised by the governor of Batangas on the ground of ultra vires. 2.3. COMELEC Resolution No. 2987 (promulgated February 10, 1998) provided the rules and regulations for the plebiscite scheduled on February 28, 1998, required by the ordinance and resolution.
  • Judicial and Procedural Developments
3.1. The petitioners filed the class suit in Civil Case No. 3442 before the Regional Trial Court (RTC) of Balayan, Batangas, Branch XI, seeking the annulment of Ordinance No. 05, Resolution No. 345, and COMELEC Resolution No. 2987, along with a prayer for a temporary restraining order (TRO) or preliminary injunction. 3.2. An ex parte motion for the issuance of a TRO was simultaneously filed to enjoin the implementation of the contested measures. 3.3. On February 25, 1998, the RTC issued an Order denying the TRO/preliminary injunction on the ground that the petitioners’ remedy against COMELEC Resolution No. 2987 should be sought before the Supreme Court, as it involved the Commission’s exercise of powers.
  • Subsequent Actions and Developments
4.1. Petitioners, asserting urgency due to the scheduled plebiscite, filed an appeal by certiorari on February 27, 1998 without filing a motion for reconsideration. 4.2. The Court, in a Resolution dated March 10, 1998, ordered the parties to maintain the status quo existing at the time of the petition’s filing. 4.3. The Solicitor General intervened through a Manifestation and Motion in lieu of Comment on August 28, 1998, concurring with the petitioners and recommending that the petition be given due course. 4.4. The Court, in subsequent resolutions in September 1998 and June 1999, ordered further submissions of comments and memoranda from the parties, with petitioners articulating the central issue regarding the jurisdiction over the COMELEC’s resolution and the splitting of the single cause of action.

Issues:

  • Jurisdiction and Proper Forum
    • Whether the Regional Trial Court had jurisdiction to issue a temporary restraining order or preliminary injunction to enjoin the execution of COMELEC Resolution No. 2987.
    • Whether compelling petitioners to seek injunction from the Supreme Court, rather than the RTC, results in multiplicity of suits or splitting of a single cause of action.
  • Nature of the COMELEC Resolution
    • Whether COMELEC Resolution No. 2987 falls within the scope of decisions that are ministerial or administrative in nature as opposed to those involving the commission’s adjudicatory or quasi-judicial functions.
    • Whether the resolution is “final” and reviewable by certiorari under Section 7, Article IX-A of the 1987 Constitution.
  • Mootness and Practical Impact
    • Whether the holding of the plebiscite on February 28, 1998, renders the petition moot and academic.
    • Whether substantial issues still remain that require judicial intervention despite the plebiscite having been conducted.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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