Title
Severino vs. Governor-General of the Philippine Islands
Case
G.R. No. 6250
Decision Date
Aug 3, 1910
Lope Severino, a private citizen, challenged the Governor-General's appointment of a municipal president instead of calling a special election. The Supreme Court ruled that Severino lacked standing, the court lacked jurisdiction over the Governor-General's discretionary acts, and dismissed the case.

Case Digest (G.R. No. 6250)
Expanded Legal Reasoning Model

Facts:

  • Petitioner's Identity: Lope Severino is a resident, qualified elector, and local chief of the Nacionalista party in Silay, Occidental Negros.
  • Election Context: On November 2, 1909, a general election was held to elect municipal officials in Silay. Emilio Gaston (Nacionalista) and Domingo Hernaez (Progresista) were candidates for municipal president. Hernaez was declared the winner based on election returns.
  • Election Protest: Gaston filed a protest under Section 27 of Act No. 1582 (Election Law). The Court of First Instance ruled on December 14, 1909, that no one was legally elected as municipal president.
  • Governor-General's Action: Instead of calling a special election as required by law, the Governor-General directed the provincial board to fill the vacancy by appointment.

Issues:

  • Standing of Petitioner: Does Lope Severino, as a private citizen and local party chief, have the legal standing to file a petition for mandamus and injunction?
  • Jurisdiction Over the Governor-General: Does the court have jurisdiction to control or compel the official acts of the Governor-General through mandamus or injunction?
  • Nature of the Governor-General’s Duty: Is the Governor-General’s decision to appoint rather than call a special election a discretionary or ministerial act?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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