Title
National Liga ng mga Barangay vs. Paredes
Case
G.R. No. 130775
Decision Date
Sep 27, 2004
The DILG's intervention in Liga ng mga Barangay’s elections overstepped constitutional bounds by exercising control, violating local autonomy. The Supreme Court ruled the DILG’s actions unconstitutional and void.

Case Summary (G.R. No. 124461)

Background of the Case

The dispute arose over the appointment of the DILG as interim caretaker of the Liga ng mga Barangay (Liga) and the scope of the DILG Secretary’s supervisory powers. Rival claims emerged regarding the valid presidency of the Caloocan City Liga chapter between Alex L. David (incumbent president) and Manuel A. Rayos. The initial complaints related to alleged irregularities in notices and conduct of the 1997 Liga elections, with challenges denying the validity of election results and appointments. The RTC issued temporary restraining orders to stop elections but these were either not properly served or short-lived.

Judicial Proceedings and DILG’s Intervention

Following petitions and counter-petitions, the DILG moved to be appointed interim caretaker to manage and administer the Liga's affairs pending proper elections, citing the President’s general supervisory power over local governments under Administrative Order No. 267 and asserting the Liga is a government organization. The trial court granted this motion, recognizing the DILG’s general supervisory jurisdiction over local governments, including leagues created under the Local Government Code, and viewed the caretakers’ management as a corollary to supervisory power, necessary to address confusion and conflicts within the Liga. Consequently, the DILG issued memoranda directing local officials not to recognize David and ordered new elections.

Petitioners’ Arguments Against DILG Appointment

Petitioners contended that:

  1. The Liga ng mga Barangay is not a local government unit (LGU) but a government organization governed primarily by its own Constitution and By-laws (Sec. 507, RA 7160), which should be free from DILG control.
  2. Elected Liga officers have vested rights and can only be removed for cause under Liga rules, and the DILG’s assumption of management and appointment of caretakers amounted to unlawful control, beyond mere supervision.
  3. The DILG’s acts, including issuing supplemental election guidelines and appointing Rayos as Liga-Caloocan President notwithstanding ongoing quo warranto proceedings, illegally supplanted the Liga’s autonomy and internal governance.
  4. Prior jurisprudence, notably Taule v. Santos, prohibits the Secretary of Local Government from invalidating or controlling the election of Liga officers, recognizing the strict constitutional limitation of supervisory power to mere oversight.

Respondents’ and Intervenor’s Positions

The DILG and election challenger Rayos maintained that:

  1. The DILG Secretary, as the President’s alter ego, has supervisory authority over all LGUs and their officials, including members of the Liga as barangay officials.
  2. Management activities conducted by the DILG as interim caretaker, limited to election supervision and organization, fall within the supervisory and rule-making remit granted by law.
  3. The petitioners failed to show legal authority invalidating the appointment of the DILG as caretaker or requiring abstention from intervention.
    Meanwhile, the Solicitor General sided with petitioners, emphasizing that the DILG’s caretaking role crossed the constitutional bounds of general supervision and constituted unconstitutional control over the Liga, which is not strictly an LGU.

Legal Issues Presented

The main issue boiled down to:

  1. Whether the Liga ng mga Barangay qualifies as a government organization subject to the DILG Secretary’s constitutional power of general supervision over local governments.
  2. Whether the trial court’s appointment of the DILG as interim caretaker and the DILG’s further acts amounted to unconstitutional exercise of control rather than mere supervision, thereby violating the principle of local autonomy under the 1987 Constitution.

Court’s Ruling on Mootness

The Court ruled the petition was not moot despite subsequent elections and turnover of Liga officers because the core constitutional question regarding the limits of DILG’s supervisory powers and the validity of the caretaker appointment remained capable of repetition yet evading review. The issues transcended electoral events, affecting local autonomy and governance principles.

Constitutional and Statutory Framework of Barangays and the Liga

Barangays are the basic political units and the primary planning and implementing units of government policies, functioning in a bottom-up approach to national development.
The Liga ng mga Barangay is the officially recognized organization of all barangays, designed to represent barangay interests in higher sanggunians (municipal, city, provincial levels) and to articulate concerns affecting barangay administration. It has chapters at municipal, city, provincial, metropolitan, and national levels.
The presidents of the Liga chapters hold ex-officio membership in the respective sanggunians during their terms.
The Local Government Code explicitly grants the Liga power to adopt its own Constitution and By-laws to govern internal affairs, provided these conform with the Constitution and existing laws. The Liga’s internal governance, including elections and management, is thus intended to be autonomous and self-regulated.

Distinction Between Supervision and Control Under the Constitution

Article X, Section 4 of the 1987 Constitution vests the President with “general supervision” over local governments, explicitly distinguished from “control.”

  • Supervision is oversight to ensure subordinates perform their duties according to law; the superior can compel compliance but cannot alter or set aside lawful acts of subordinates.
  • Control entails the authority to alter, modify, nullify, or substitute one’s own judgment over that of a subordinate, a power not conferred by the Constitution to the President over local governments or their leagues.
    This distinction is crucial to respecting local autonomy and preventing unconstitutional interference.

Precedents on Limits of Supervisory Power

The Court relied on prior rulings:

  • Mondano v. Silvosa (1995) defined supervision and control distinctively.
  • Taule v. Santos (1991) invalidated the Secretary of Local Government’s attempt to nullify the election of barangay council officials, upholding the limitation of supervisory power to mere oversight.
  • Drilon v. Lim (1994) clarified that supervisory officials cannot lay down or modify rules but may ensure compliance with existing legal rules.
  • Bito-Onon v. Fernandez (2001) affirmed the President’s supervision extends to the Liga ng mga Barangay, as a government organization composed of elected barangay officials; however, such supervision cannot include control or interference in their internal affairs.

Application to the Case

The Court found:

  • The League, although not an LGU per se, is a government

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