Case Summary (G.R. No. 126858)
Petitioner’s Claim and Prayer
The Municipality of San Narciso filed a quo warranto petition in June 1989 seeking:
- Nullification of Executive Order No. 353 (creating San Andres municipal district).
- Permanent injunction barring San Andres officials from exercising municipal functions.
Respondents’ Defenses
• Estoppel: San Narciso initially requested the creation of San Andres (Resolution No. 8, May 1959).
• Laches and de facto status: San Andres has functioned as a municipality since 1959.
• Improper party: Quo warranto prerogative belongs to the State (Solicitor General).
• Mootness: Republic Act No. 7160 (Local Government Code, 1991) constitutionally validated existing municipal districts under Section 442(d).
Key Dates
• August 20, 1959: EO 353 issues, creating San Andres municipal district.
• October 5, 1965: EO 174 recognizes San Andres as a fifth‐class municipality, effective July 1, 1963.
• June 5, 1989: Petition for quo warranto filed.
• July 18, 1991: RTC defers dismissal motions; denies judgment on pleadings.
• November 27, 1991: San Andres moves to dismiss as moot under RA 7160.
• December 2, 1991: RTC dismisses petition for lack of cause of action; recognizes RA 7160 cure.
• January 17, 1992: RTC denies reconsideration.
• December 6, 1994: Supreme Court decision.
Applicable Law
• 1987 Philippine Constitution (separation of powers, Article VI).
• Revised Administrative Code, Art. VI, Ch. 64 (then in force).
• Republic Act No. 1515 (classification of municipal districts).
• Republic Act No. 7160 (Local Government Code of 1991), Sec. 442(d).
• Rules of Court, Rules 42, 45 (certiorari); Rules 65/66 (quo warranto).
Facts
- San Narciso sought segregation of six barrios to improve local development (Resolution No. 8, May 1959).
- President Garcia issued EO 353 (Aug. 20, 1959), creating San Andres as a municipal district.
- President Macapagal’s EO 174 (Oct. 5, 1965) elevated it to a fifth‐class municipality under RA 1515.
- San Andres consistently operated with elected officials, generated revenues, and featured in judicial reorganization and legislative apportionment.
Procedural History
• RTC Branch 62 initially delayed dismissal, then granted San Andres’s motion, finding the petition moot and that RA 7160 cured any defect.
• RTC held that municipal‐district defects were cured by the Local Government Code’s retrospective validation.
Issues
- Can a municipal entity, created by an allegedly unconstitutional executive order, have its existence challenged by quo warranto after decades of operation?
- Does Section 442(d) of RA 7160 validly cure any constitutional defect under the 1987 Constitution’s separation of powers?
- Is San Narciso a proper party to invoke quo warranto against a municipal district?
Supreme Court Ruling
The petition was dismissed. San Andres is now a de jure municipality.
Rationale
- Timeliness and Laches: A quo warranto challenge must be timely. San Narciso waited nearly thirty years before filing. Public interest and stability demand prompt challenges.
- De Facto and De Jure Recognition: Continuous exercise of municipal powers, classification under RA 1515, judicial reorganization assignments, and legislative apportionment demonstrate State recognition. Such long‐st
Case Syllabus (G.R. No. 126858)
Facts
- On 20 August 1959, President Carlos P. Garcia issued Executive Order No. 353, creating the municipal district of San Andres, Quezon by segregating six barrios and their sitios from San Narciso, Quezon
- The creation was requested by the municipal council of San Narciso through Resolution No. 8 dated 24 May 1959, citing local development needs despite minimum wage constraints
- By Executive Order No. 174 (5 October 1965), President Diosdado Macapagal recognized San Andres’s status as a fifth-class municipality effective 1 July 1963, pursuant to Republic Act No. 1515
- On 5 June 1989, the Municipality of San Narciso filed a quo warranto petition with the Regional Trial Court (Special Civil Action No. 2014-G) to declare EO No. 353 null and void and to enjoin San Andres officials from exercising municipal functions
Procedural History
- Respondents moved to dismiss, asserting estoppel, the maturity of San Andres’s corporate personality, and that quo warranto must be brought by the State through the Solicitor General
- On 27 November 1991, San Andres renewed its motion, contending the petition was moot and academic by virtue of Section 442(d) of Republic Act No. 7160 (Local Government Code of 1991)
- The trial court granted the motion and dismissed the petition on 2 December 1991 for lack of cause of action and held that RA 7160 cured any defect in presidentially created municipal districts
- A motion for reconsideration was denied on 17 January 1992, prompting the present petition for certiorari before the Supreme