Case Summary (G.R. No. 154599)
Procedural Background
The petitioner filed a petition for certiorari under Rule 65 of the Rules of Court, seeking to nullify the aforementioned city ordinance and executive order, arguing that they were contrary to law. The Liga, as the national organization of barangays, asserted that the ordinance encroached upon its constitutionally derived functions and procedural rights in governance as outlined in the Local Government Code of 1991 (Republic Act No. 7160).
League Constitution and By-Laws
The Liga adopted its Constitution and By-Laws to govern its internal organization. Specifically, Section 1, third paragraph, Article XI of the Liga's governing document stipulates that election matters not covered by the Constitution and By-Laws would be governed by the Liga Election Code or other rules promulgated by the Liga’s Executive Board. The Liga also established a synchronized election schedule for its chapters, reflecting the legal provisions intended to ensure proper governance.
Manila City Ordinance and Executive Order
Ordinance No. 8039 mandated an election framework for representatives of the District Chapters within the Manila City Chapter of the Liga. It outlined the election processes, which contradicted the Liga’s established procedures for direct elections. Following the City's enactment of the ordinance, Mayor Atienza approved it and issued the related executive order to operationalize the new election framework.
Petitioner's Allegations
The Liga contended that Ordinance No. 8039 and Executive Order No. 011 were invalid as they contradicted the Liga Election Code, thereby infringing on the rights to a direct election framework. The Liga formally requested the mayor to veto the ordinance on the grounds of its illegality, citing legislative overreach by the City Council.
Application for Temporary Restraining Order
In addition to nullification, the petitioner sought a temporary restraining order to prevent the implementation of the ordinance, arguing that the elections were imminent and that granting a restraining order was imperative to preserve the Liga's constitutional rights as it pertained to the election process.
Arguments from the Respondents
The respondents defended the legality of the ordinance, positing that the issuance of the ordinance and executive order fell within the City Council's legislative authority. They argued that certiorari was an inappropriate remedy because it is meant for judicial or quasi-judicial actions, which was not applicable in this case since legislative and executive functions had been executed.
Jurisdictional Issues
The Supreme Court elaborated that the respondents did not act within any judicial or quasi-judicial capacity; thus, certiorari would not lie. The case leaned more towards a declaratory relief issue that is under the exclusive jurisdiction of lower courts, rather than that of th
...continue readingCase Syllabus (G.R. No. 154599)
Case Overview
- The petition for certiorari under Rule 65 aims to nullify Manila City Ordinance No. 8039, Series of 2002, and Executive Order No. 011, Series of 2002, both deemed contrary to law.
- The Liga ng mga Barangay National (Liga) represents the barangays in the Philippines, constituted by duly elected presidents of local chapters as mandated by the Local Government Code (Republic Act No. 7160).
- The Liga's Constitution and By-Laws, adopted on 16 March 2000, outline its internal governance and electoral procedures.
Legislative Background
- Section 492 of the Local Government Code establishes the Liga as the national organization for barangays, while Section 493 mandates the election of officers at various levels.
- The Liga adopted its Election Code defining the conduct of elections for its chapters, emphasizing direct elections for officers.
Ordinance and Executive Order Details
- The City Council of Manila enacted Ordinance No. 8039 on 28 June 2002, which altered the election process for the Liga's officers and established a different timeline for elections.
- The ordinance mandated that elections for the City Chapter occur thirty days after the barangay elections, which the Liga contends is an encroachment on its constitutionally established process.
Issues Presented
- Whether ...continue reading