Title
Sanciangco vs. Rono
Case
G.R. No. L-68709
Decision Date
Jul 19, 1985
Appointive official deemed resigned upon filing candidacy; SC ruled Section 13(1) applies, distinguishing elective/appointive roles under BP 697.

Case Digest (G.R. No. L-68709)
Expanded Legal Reasoning Model

Facts:

  • Background of the Petitioner
    • Petitioner, Napoleon E. Sanciangco, was elected Barangay Captain of Barangay Sta. Cruz, Ozamiz City in the May 17, 1982 Barangay elections.
    • He was subsequently elected President of the Association of Barangay Councils (ABC) of Ozamiz City by the members of that association.
    • By virtue of his position as President of the ABC, he was appointed by the President of the Philippines as an ex officio member of the Sangguniang Panlungsod (City Council) of Ozamiz City, pursuant to Section 3, paragraph 1 of Batas Pambansa Blg. 51.
  • Filing of the Certificate of Candidacy and Subsequent Developments
    • On March 27, 1984, petitioner filed his Certificate of Candidacy for the May 14, 1984 Batasang Pambansa elections under the banner of the Mindanao Alliance for Misamis Occidental.
    • Upon filing his certificate, he later informed the respondent, Vice-Mayor Benjamin A. Fuentes, who was the Presiding Officer of the Sangguniang Panlungsod, that he was resuming his duties as a member of the Council.
    • The issue arose as petitioner's candidacy triggered the application of Section 13 of Batas Pambansa Blg. 697, which provides that:
      • Subsection (1): Any person holding a public appointive office or position ceases to hold office upon filing a certificate of candidacy.
      • Subsection (2): Elective officials such as governors, mayors, members of sanggunians, or barangay officials are considered to be on forced leave of absence upon filing their certificate.
    • The controversy centered on whether petitioner, who held an appointive position (as an ex officio member based on his ABC presidency), should be treated as having resigned from his office (ipso facto ceasing to be a member of the Council) or should be considered as merely placed on forced leave of absence.
  • Actions by Local Government Officials
    • Respondent Minister of Local Government Jose A. Rono ruled that since petitioner held an appointive office, his filing of the certificate of candidacy automatically resulted in his resignation from his position.
    • This ruling was supported by the interpretation that Section 13(1) of Batas Pambansa Blg. 697 clearly applies to persons holding appointive public offices, a category under which petitioner's position falls.
  • Legislative History and Context
    • The legislative debate during the Batasang Pambansa clarified that the provision distinguishes between public officials based on the mode of their appointment:
      • Appointive local officials (covered under paragraph 1) and
      • Elected (elective) local officials (covered under paragraph 2).
    • Transcripts of the proceedings indicated that while some argued the law made no distinction between elective and appointive positions, the consensus was that appointive officials indeed fell squarely within the ambit of subsection (1).
    • Additionally, the Local Government Code (B.P. Blg. 337) also reiterated the appointive character of the membership in the Sangguniang Panlungsod.

Issues:

  • The Primary Legal Issue
    • Whether an appointive member of the Sangguniang Panlungsod is deemed to have resigned from office upon filing his certificate of candidacy for the Batasang Pambansa elections.
    • Whether the statutory provision (Section 13 of Batas Pambansa Blg. 697) should be interpreted uniformly for both elective and appointive officials, or if the legislative intent supports a distinction between the two.
  • Secondary Considerations
    • Whether petitioner's contention that the statute makes no distinction between elective and appointive officials is tenable.
    • Whether the application of the provision violated any constitutional or procedural due process rights, particularly the equal protection clause.
    • The implications of the legislative debate and the usage of interpretive principles such as noscitur a sociis, in determining the proper classification of petitioner's office.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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