Case Summary (G.R. No. 132603)
Factual Background
On February 23, 1998, the petitioners filed a class suit before the Regional Trial Court of Balayan, Batangas, seeking the annulment of Ordinance No. 05 and Resolution No. 345, which were enacted by the Sangguniang Panglalawigan of Batangas, and COMELEC Resolution No. 2987. Ordinance No. 05 ordered the abolition of barangay San Rafael and its merger with barangay Dacanlao, stipulating that a plebiscite be conducted by the COMELEC in accordance with the Local Government Code of 1991. The Governor of Batangas had vetoed this ordinance, asserting it was ultra vires, primarily due to the absence of necessary attestations from various government departments.
Procedural History
Immediately following the filing of the action, the petitioners sought a temporary restraining order to prevent the COMELEC from enforcing the ordinance and resolutions. On February 25, 1998, the trial court denied this motion, citing a lack of jurisdiction since any challenge to COMELEC decisions must be addressed to the Supreme Court. The petitioners subsequently filed an appeal before the Supreme Court on February 27, 1998.
Issues Presented
The primary issue raised by the petitioners is whether the Regional Trial Court had jurisdiction to issue a temporary restraining order against the implementation of COMELEC Resolution No. 2987 while the annulment case was pending. They argued that the trial court's order encouraged multiplicity of suits contrary to procedural rules and that the actions of COMELEC in scheduling the plebiscite were administrative, not quasi-judicial, thus reviewable by the trial court.
Arguments of the Petitioners
The petitioners contended that the trial court’s decision was contrary to law as it forced them to seek relief from multiple courts, thus splitting their cause of action. They further asserted that when the COMELEC performs ministerial duties, such as conducting a plebiscite in compliance with an ordinance, that its actions should not fall under the purview of the Supreme Court's exclusive review. Even though the plebiscite had occurred, they maintained that the case was not moot due to ongoing constitutional implications.
Position of the Solicitor General
The Solicitor General supported the petitioners’ position, stating that the issuance of COMELEC Resolution No. 2987 was a ministerial duty and should not be subject to exclusive review by the Supreme Court. The General also referred to previous cases that characterized COMELEC actions as reviewable only when they exercised adjudicatory functions.
Decision of the Supreme Court
The Supreme Court found merit in the petitioners’ arguments, emphasizing that the provisions of the 1987 Constitution, specifically Section 7 of Article IX-A, pertain prima
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Case Overview
- This case is an appeal by certiorari under Rule 45 of the Rules of Court.
- The petitioners aim to reverse the Order dated February 25, 1998, from the Regional Trial Court of Balayan, Batangas, which denied the issuance of a temporary restraining order and/or preliminary injunction against the Commission on Elections (COMELEC).
- The case revolves around the scheduled plebiscite on February 28, 1998, concerning the abolition of barangay San Rafael and its merger with barangay Dacanlao, municipality of Calaca, Batangas.
Background of the Case
- Petitioners, officials and residents of barangay San Rafael, filed a class suit against multiple respondents, including the Sangguniang Panglalawigan of Batangas and COMELEC.
- The suit was initiated to annul Ordinance No. 05 and Resolution No. 345, enacted by the Sangguniang Panglalawigan, along with COMELEC Resolution No. 2987.
- Ordinance No. 05 declared the abolition of barangay San Rafael, necessitating a plebiscite under Sections 9 and 10 of Republic Act No. 7160 (Local Government Code of 1991).
Orders and Resolutions Involved
- Ordinance No. 05 instructed COMELEC to conduct the plebiscite but was previously vetoed by the governor of Batangas for being ultra vires, due to lack of required certifications from government departments.
- Resolution No. 345 a