G.R. No. 108399 - Alu III vs. Mirasol

The Local Government Code, effective January 1, 1992, mandates the first election for the Sangguniang Kabataan (SK) to occur thirty days after the next local election.
The first local election under this Code was held on May 11, 1992, leading to the Commission on Elections (COMELEC) issuing Resolution No. 2499 for SK elections on September 30, 1992.
The Department of the Interior and Local Government (DILG), through Secretary Rafael M. Alunan III, exempted Manila from holding SK elections, citing a previous election on May 26, 1990 as the first under the new Code.
Private respondents challenged this exemption in the Regional Trial Court (RTC) of Manila, arguing that the DILG lacked authority to amend COMELEC resolutions and that the exemption violated their right to equal protection under the law.

Petitioners argued that the DILG Secretary had the authority to determine exemptions under Section 532(d) of the Local Government Code.
The RTC ruled that the DILG Secretary could not exempt Manila from the elections, asserting that the power to enforce election laws is vested solely in the COMELEC.
The court found that the COMELEC had already determined that no prior elections had occurred in Manila, thus necessitating the December 4, 1992 elections.

The preliminary issue was whether the subsequent elections on May 13, 1996 rendered the case moot.
The court concluded that the case was not moot, as it involved questions likely to recur in future elections and could evade judicial review.
The potential invalidity of the May 26, 1990 KB elections in Manila was also a concern, as the court had previously enjoined their enforcement.

The court upheld the constitutionality of COMELEC Resolution No. 2499, which placed SK elections under the DILG's direct control and supervision.
It clarified that elections for SK officers do not fall under the jurisdiction of the COMELEC, as they are distinct from barangay elections.
The court emphasized that the DILG's role was to enforce the rules set forth by the COMELEC, not to create new regulations.

The DILG was tasked with determining which barangays were exempt from the December 4, 1992 elections based on prior kabataang barangay elections.
The authority to ascertain whether elections had been held in specific barangays was deemed a factual determination within the DILG's supervisory role.
The court found that the DILG's actions were consistent with legislative intent and did not constitute an undue delegation of power.

Section 532(d) of the Local Government Code was recognized as a curative law, validating prior kabataang barangay elections held between January 1, 1988, and January 1, 1992.
The law aimed to prevent questions regarding the validity of these elections and to ensure continuity in governance.
The court affirmed that curative laws are permissible and serve to validate acts that would otherwise be invalid under existing laws.

Respondents contended that exempting Manila's barangays from the December 4, 1992 elections violated the equal protection clause, as other barangays were allowed to hold elections.
The court found that the mere existence of prior elections in other barangays did not establish discrimination against Manila's youth voters.
It concluded that the exemption was lawful, as Manila had alrea...continue reading