Case Summary (G.R. No. 141307)
Factual Background
During the local elections held on May 11, 1997, Cesar M. Calimlim was elected as Mayor and Baltazar Aquino as Vice-Mayor, both representing the Lakas NUCD-KAMPI political party. Other members of the Sangguniang Bayan, including petitioners sourced from the REFORMA-LM party, were elected. Upon Mayor Calimlim's death on March 25, 1999, Vice-Mayor Aquino ascended to the mayoral position, thereby vacating the vice-mayoral role, which led to petitioner Danny B. Tamayo being appointed as Vice-Mayor. Following this transition, Governor Victor Agbayani appointed Purto J. Navarro to fill the vacancy created in the Sanggunian Bayan.
Legal Proceedings
Respondents contested Navarro’s appointment by filing Civil Case No. 99-12958-D in the Regional Trial Court, claiming that the appointment was invalid as it did not align with the legal requirements established under Republic Act 7160, the Local Government Code of 1991. They argued that the political appointee should have belonged to the Lakas-NUCD-KAMPI party, as it was the former Vice-Mayor's elevation to Mayor that created the vacancy in the Sangguniang Bayan.
Court of Appeals Ruling
The Court of Appeals ruled on October 7, 1999, in favor of the private respondents, concluding that Mayor Calimlim’s death initiated a chain of vacancies that resulted in a reshuffling of positions within the Sangguniang Bayan. Their interpretation suggested that the last vacancy was not the one created by Tamayo's elevation but rather by the subsequent movements down the line of councilors, ultimately linking the validity of Navarro's appointment to membership in the Lakas-NUCD-KAMPI party.
Supreme Court Analysis
Upon reviewing the case, the Supreme Court identified that the resolution of vacancies and succession is dictated by Sections 44 and 45 of RA 7160. The legal framework stipulates that the nominations for appointments to fill permanent vacancies in the Sangguniang Bayan must adhere to party affiliation, thereby ensuring continued political representation aligned with electoral will. The Court noted that the "last vacancy" referred to the one generated by Tamayo's elevation to Vice-Mayor, necessitating that Navarro be appointed from the same political affiliation (REFORMA-LM) as Tamayo, maintaining the democratic intent behind local government representation.
Verification and Procedural Matters
The Court addressed respondents’ claims regarding defects in the verification process o
...continue readingCase Syllabus (G.R. No. 141307)
Case Overview
- This case was decided by the Supreme Court of the Philippines, under G.R. No. 141307, on March 28, 2001.
- The petitioners, Purto J. Navarro and Danny B. Tamayo, sought a review on certiorari concerning a decision made by the Court of Appeals that annulled Navarro's appointment to the Sanggunian Bayan of Mapandan, Pangasinan.
Background Facts
- In the local elections of May 11, 1997, the elected officials of the Municipality of Mapandan, Pangasinan included:
- Cesar M. Calimlim as Mayor (Lakas NUCD-KAMPI)
- Baltazar Aquino as Vice-Mayor (Lakas NUCD-KAMPI)
- Several members of the Sangguniang Bayan, with Danny B. Tamayo (REFORMA-LM) receiving the highest number of votes.
- On March 25, 1999, Mayor Cesar Calimlim passed away, leading to a vacancy in the mayoralty that was filled by Vice-Mayor Baltazar Aquino.
- Danny B. Tamayo, as the highest-ranking member of the Sangguniang Bayan, was elevated to Vice-Mayor, creating a vacancy in the Sangguniang Bayan.
- Governor Victor Agbayani appointed Purto J. Navarro, a member of the same political party as Tamayo (REFORMA-LM), to fill the vacancy left by Tamayo.
Legal Proceedings
- Respondents challenged Navarro’s appointment by filing Civil Case No. 99-12958-D at the Regional Trial Court of Dagupan City, which was presided over by Judge Crispin Laron.
- After the court denied their motions for a temporary restraining order and for the inhibition of Judge Laron, the respondents escalated the matter to the Court o