Case Summary (G.R. No. 80391)
Petition and Procedural History
Petitioner sought:
(a) Prohibition of assembly sessions from Nov. 5, 1987 onward;
(b) Declaration that Nov. 2, 1987 proceedings void;
(c) Validation of his March 12, 1987 election as Speaker;
(d) Permanent injunction.
Pending resolution, the Assembly adopted a resolution expelling Limbona for allegedly usurping pay authority and improperly withdrawing Assembly funds, and for filing this Supreme Court petition. Respondents contended the petition was moot and academic.
Expulsion and Due Process
The Court held the expulsion resolution ineffective because:
– No evidence of notice or hearing; due process requires at least opportunity to be heard.
– Charges were unsubstantiated accusations; no formal investigation or chance to rebut.
– Retaliatory nature: expulsion threatened for seeking judicial remedy, which is constitutionally protected.
Accordingly, Limbona’s expulsion did not render the case moot, and he was entitled to reinstatement unless properly removed after due process.
Scope of Judicial Jurisdiction Over Autonomous Regions
Issue: whether national courts may review acts of “autonomous” governments under PD 1618.
– PD 1618 created “internal autonomy” for Regions IX and XII “within the framework of national sovereignty and territorial integrity” with legislative and executive machinery.
– The President retains “general supervision and control” (PD 1618, Sec. 35) to ensure compliance with national law and policies.
– Sangguniang Pampook’s powers (PD 1618, Sec. 7) are chiefly administrative and subject to presidential oversight.
Conclusion: the autonomy granted was one of administrative decentralization, not complete political independence; thus, the Supreme Court has jurisdiction to review internal acts, including removal of members and officers.
Autonomy: Administration vs. Political Power
– Administrative decentralization: local units manage internal affairs, remain under central supervision, and cannot dispense with national oversight.
– Political decentralization: full self-government, accountable only to constituents.
– PD 1618 exemplifies administrative decentralization—autonomy “within the framework” of national sovereignty, with presidential supervisory power—so its acts are judicially reviewable.
Validity of the Sessions and the Claimed Recess
Background
– Oct. 21, 1987: House Committee on Muslim Affairs invited Limbona to assist in hearings Nov. 1–15, 1987.
– Limbona instructed Acting Secretary to announce a “recess” of the Assembly for that period.
Respondents’ Challenge
– Held sessions on Nov. 2 and 5, 1987, declared his speakership vacant, and elected presiding officers.
Rules Issue
– Sangguniang Pampook Rules allow recess only at the Speaker’s discretion during session; sessions cannot be adjou
Case Syllabus (G.R. No. 80391)
Facts
- On September 24, 1986, Sultan Alimbusar P. Limbona was appointed member of the Sangguniang Pampook, Regional Autonomous Government, Region XII, representing Lanao del Sur.
- On March 12, 1987, he was elected Speaker of the Regional Legislative Assembly (Batasang Pampook) of Central Mindanao (Region XII).
- Assembly membership: 18 members; two (Acmad Tomawis, Rakil Dagalangit) filed certificates of candidacy for Congress on March 23, 1987, later withdrew, and resumed Assembly seats.
- On October 21, 1987, Congressman Datu Guimid Matalam, Chairman of the House Committee on Muslim Affairs, invited the Region XII Speaker and delegates to a congressional hearing (Nov 1–15, 1987) on autonomous governments.
- Pursuant to that invitation, Speaker Limbona telegraphed Acting Secretary Johnny Alimbuyao to notify Assembly members that “there shall be no session in November” because attendance at the congressional hearing “takes precedence.”
- On November 2 and 5, 1987, a group of Assemblymen met without the Speaker, declared his office vacant, and authorized the Speaker Pro‐Tempore to preside and reconfirmed a new Acting Secretary.
Petition
- Petitioner sought:
• A restraining order or preliminary injunction enjoining respondents from further sessions (Nov 5, 1987, and thereafter)
• Declaration that the November 2, 1987, session was null and void
• Recognition of his March 12, 1987 election as Speaker as valid and subsisting
• Permanent injunction against respondents’ sessions
• Other just and equitable relief
Expulsion Resolution
- On January 19, 1988, respondents filed a resolution expelling Limbona from the Sangguniang Pampook, Region XII, alleging:
• Unauthorized payment of salaries/emoluments to a member (Odin Abdula) who resigned upon filing candidacy
• Unauthorized cash withdrawals causing salary non‐payment to