Case Summary (G.R. No. L-70203)
Jurisdictional Issue
Central to this dispute is the question of jurisdiction. The petitioners argue that the Regional Trial Court (RTC) does not have jurisdiction over quo warranto proceedings concerning the qualifications of candidates for the Board of Directors of an electric cooperative. Instead, they assert that such authority resides with the National Electrification Administration (NEA), which supervises all electric cooperatives, including the procedural aspects of candidate qualifications.
Background of the Dispute
On January 30, 1985, Abante submitted a petition to disqualify Fortuno to the NEA, on grounds that Fortuno was not a resident of the pertinent district. This petition was endorsed to the CASURECO II Board, which eventually referred the issue to the District Election Committee (DEC). The DEC, after conducting a hearing, upheld Fortuno’s eligibility, concluding that he indeed qualified as a resident of District V. Subsequently, Fortuno won the election on February 9, 1985, garnering a substantial majority of votes.
RTC Actions and Subsequent Petitions
Following the election, Abante filed a quo warranto petition in RTC Naga City, requesting a preliminary injunction to prevent Fortuno from assuming office. The RTC ruled on March 13, 1985, affirming its jurisdiction over the matter despite objections from the defendants regarding the validity of the procedures followed by the DEC. The court's subsequent orders aimed to restrain Fortuno from performing his duties until the court resolved the litigation.
Argumentation on Jurisdiction
Petitioners Fortuno and CASURECO II contended that the NEA had exclusive jurisdiction over such electoral disputes, particularly citing relevant provisions of Presidential Decree No. 269, which outlined the powers of the NEA and the responsibilities of the DEC regarding electoral matters. They emphasized that the DEC's decision regarding Fortuno’s residency had become final and unimpeachable due to a lack of appeal from Abante within the prescribed timeframe.
Court's Findings on Quo Warranto
Upon examination of the legal framework surrounding quo warranto proceedings, the court acknowledged the definition and procedural nuances of this legal remedy. Section 1, Rule 66 of the Rules of Court provides for the use of quo warranto to challenge the eligibility of individuals to hold public office, including positions within private corporations that exercise public functions. The court framed the case as justici
...continue readingCase Syllabus (G.R. No. L-70203)
Case Overview
- The case involves a petition for certiorari and prohibition filed by Salvio B. Fortuno and Camarines Sur II Electric Cooperative (CASURECO II) against Honorable Mericia B. Palma and Joel David S. Abante.
- The primary issue is the jurisdiction of the Regional Trial Court (RTC) over quo warranto proceedings concerning the qualification of a director for an electric cooperative.
Background of the Case
- Salvio B. Fortuno and Joel David S. Abante were candidates for the position of director for District V of CASURECO II in elections held on February 9, 1985.
- On January 30, 1985, Abante petitioned the National Electrification Administration (NEA) to disqualify Fortuno, claiming he was not a resident of the area.
- The NEA directed CASURECO II's Board to act on the petition, leading to a referral to the District Election Committee (DEC).
Proceedings Prior to the Quo Warranto Petition
- The DEC denied Abante's petition after a hearing on February 8, 1985, concluding Fortuno was a resident of District V.
- The election on February 9 resulted in Fortuno winning with 1,429 votes to Abante's 637 votes, with the DEC subsequently proclaiming Fortuno as the duly elected director.
- Following the election, on February 18, 1985, Abante filed