Case Digest (G.R. No. 255453)
Facts:
Sangguniang Panlungsod ng Valenzuela City v. Janine Alexandra R. Carlos, G.R. Nos. 255453 and 255543, promulgated October 14, 2024, Supreme Court Third Division, Carandang, J., writing for the Court.Petitioner Sangguniang Panlungsod ng Valenzuela City (the Sanggunian) and several of its members, together with SK Chairperson Chiqui Marie N. Carreon (installed by the Pederasyon and recognized by the Sanggunian), challenged the actions of respondent Janine Alexandra R. Carlos, elected SK Chairperson of Brgy. Marulas who was also elected SK Federation President and served as an ex‑officio member of the Sangguniang Panlungsod of Valenzuela City.
Carlos was elected SK chairperson on May 22, 2018 and thereafter elected SK Federation President. The Pederasyon members complained that Carlos was frequently absent and uncooperative, preventing the Federation from initiating its programs. On September 29, 2018, 31 of 33 Pederasyon members passed a resolution installing Carreon as Federation President; the Sanggunian approved this by Resolution No. 1169 on October 1, 2018. Carlos filed a petition for certiorari in the Regional Trial Court (RTC), alleging removal without due process and contending that the Joint Memorandum Circular (JMC) No. 2017‑01 required complaints to be filed with the Office of the President (OP).
Separately, a local administrative complaint was filed against Carlos on October 16, 2018 alleging failure to prepare the Comprehensive Barangay Youth Development Plan and Annual Barangay Youth Investment Program in violation of R.A. No. 10742 (SK Reform Act). The Sanggunian, acting quasi‑judicially, found Carlos guilty and removed her as SK chairperson on January 21, 2019; its decision declared the removal final and executory.
Carlos sought relief in the RTC, which dismissed her certiorari petition for lack of jurisdiction and held she should have appealed to the OP under Sections 35 and 38 of JMC No. 2017‑01 within 30 days. Carlos then filed two appeals to the Court of Appeals (CA): CA‑G.R. SP No. 160131 (challenging removal as SK Federation President) and CA‑G.R. SP No. 162895 (challenging removal as SK chairperson).
In CA‑G.R. SP No. 160131 (June 19, 2019), the CA reversed the RTC and declared Sanggunian Resolution No. 1169 void for lack of jurisdiction, holding Section 32 of JMC No. 2017‑01 vested the OP with authority to hear complaints against SK Federation Presidents in highly urbanized cities. In CA‑G.R. SP No. 162895 (June 30, 2020), however, the CA affirmed the RTC and sustained Carlos’ removal as SK chairperson under R.A. No. 10742, finding she was afforded due process and failed to contest the administrative complaint. The CA later consolidated the two cases and, in its Consolidated Resolution (January 13, 2021), denied motions for reconsideration.
Carlos filed consolidated Petitions for Review on Cert...(Subscriber-Only)
Issues:
- May the Sangguniang Panlungsod of a highly urbanized city remove an SK Federation President from office?
- May the Sangguniang Panlungsod of a highly urbanized city remove an SK chairperson from office without court intervention?
- Does the removal of an SK chairperson by the Sangguniang Panlungsod also constitute removal of that officer...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)