Case Summary (G.R. No. L-68709)
Applicable Law and Legal Provisions
The resolution of the controversy rests on Section 13 of Batas Pambansa Blg. 697, which dictates the effects of filing a certificate of candidacy. Subsection 1 concerns individuals in public appointive positions, stating they cease to hold office immediately upon the filing of their candidacy, while Subsection 2 states that mayors, members of the sanggunians, and barangay officials are considered on forced leave upon filing.
Facts of the Case
Sanciangco was appointed as a member of the Sangguniang Panlungsod after being elected President of the ABC following his election as Barangay Captain. He filed his Certificate of Candidacy for the Batasang Pambansa elections but was unsuccessful. Upon filing his candidacy, Sanciangco communicated to the Vice Mayor that he intended to resume his duties on the Sangguniang Panlungsod, asserting his right based on Batas Pambansa Blg. 697. However, the Minister of Local Government ruled that he was deemed to have resigned his appointive position.
Petitioner's Argument
Sanciangco contended that there is no distinction in the legislation between elective and appointive officials, arguing that Section 13(2) of Batas Pambansa Blg. 697 includes appointive officials like him. He maintained that the intent of the law was to ensure that both appointive and elective barangay officials are substantively treated under the same conditions regarding their status upon filing a candidacy.
Respondents’ Position
The respondents, particularly the Minister of Local Government, maintained that since Sanciangco holds an appointive position, he automatically ceased to be a member of the Sangguniang Panlungsod upon his filing of the Certificate of Candidacy, as articulated in subsection 1 of Section 13, which explicitly refers to individuals in public appointive positions.
Judicial Interpretation and Ruling
The court determined that Sanciangco indeed falls under the ipso facto cessation of office stipulated in Section 13(1) because he occupies an appointive role, resulting in his automatic resignation upon filing for candidacy. The legislative intent behind the distinction was clarified; the provisions underscored that those in appointive capacities are governed by subsection 1, whereas subsection 2 applies specifically to elective officials.
Legislative Intent and Context
The legislative debates surrounding Batas Pambansa Blg. 697 further emphasized that the classifications established in Section 13 were i
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Case Information
- Petitioner: Napoleon E. Sanciangco
- Respondents: The Honorable Jose A. Rono, Minister of Local Government; The Sangguniang Panlungsod of Ozamiz City; Members of the Sangguniang Panlungsod of Ozamiz City including the Vice Mayor
- Court: Supreme Court of the Philippines
- Date of Decision: July 19, 1985
- Jurisprudence Reference: 222 Phil. 181 EN BANC
- G.R. No.: 68709
Background of the Case
- The case concerns the interpretation of the effects of filing a Certificate of Candidacy under Section 13 of Batas Pambansa Blg. 697.
- The specific issue is whether an appointive member of the Sangguniang Panlungsod who filed for candidacy in the May 14, 1984 elections should be considered resigned or on forced leave of absence upon filing the certificate.
Legal Provisions in Question
- Batas Pambansa Blg. 697, Section 13:
- Subsection (1): States that any person in a public appointive office ceases to hold office upon filing a certificate of candidacy.
- Subsection (2): Specifies that governors, mayors, members of various sanggunians, or barangay officials are considered on forced leave of absence upon filing a certificate of candidacy.
Facts of the Case
- Petitioner Sanciangco was elected Barangay Captain of Barangay Sta. Cruz, Ozamiz City, in 1982 and later became President of the Association of Barangay Councils (ABC).
- He was appointed to the Sangguniang Panlungsod due to his position as ABC President.
- On March 27, 1984, he filed his Certificate of Candidacy for the Batasan Pambansa elections but was unsuccessful.
- Af