G.R. No. 255453 - Sangguniang Panlungsod ng Valenzuela City vs. Carlos

Case Summary (G.R. No. 255453)

Factual Background

Janine Alexandra R. Carlos was elected SK Chairperson of Barangay Marulas on May 22, 2018 and was the elected president of the Pederasyon ng mga SK of Valenzuela City, thereby becoming an ex-officio member of the Sangguniang Panlungsod. During her tenure, the SK Pederasyon accused Carlos of chronic absence and uncooperative conduct that prevented the Pederasyon from initiating projects. On September 29, 2018, thirty-one of thirty-three Pederasyon members approved the installation of Vice President Chiqui Marie N. Carreon as the new Pederasyon president. The Sangguniang Panlungsod of Valenzuela City recognized that action by adopting Resolution No. 1169 on October 1, 2018.

Administrative Complaint and Sanggunian Action

On October 16, 2018, private complainants Enrico Mauhay and Reniel Montanez filed a joint administrative complaint with the Sangguniang Panlungsod Secretariat alleging that Carlos had failed, within the prescribed period, to submit the Comprehensive Barangay Youth Development Plan and the Annual Barangay Youth Investment Program in violation of R.A. No. 10742. The Sangguniang Panlungsod, acting as a quasi-judicial body, rendered a Decision dated January 21, 2019 finding Carlos guilty of violating Section 18(d) of R.A. No. 10742 and meted the penalty of removal from office, declaring the decision final and executory.

Proceedings in the Regional Trial Court

Carlos filed a petition for certiorari before the Regional Trial Court of Valenzuela City challenging her alleged removal as Pederasyon president on grounds of lack of due process and incorrect procedural venue under JMC No. 2017-01. The RTC, by Resolution dated February 18, 2019, dismissed the petition for lack of jurisdiction and for failure to avail of the remedy of appeal to the Office of the President within thirty days under Sections 35 and 38 of JMC No. 2017-01. The RTC observed that Carlos knew of the Sanggunian decision on October 1, 2018, filed a motion for reconsideration on October 5, 2018 which the Sanggunian did not act upon, and thus the period to appeal to the Office of the President had lapsed.

Court of Appeals Decision in CA-G.R. SP No. 160131

In CA-G.R. SP No. 160131, which concerned Carlos’s removal as Pederasyon president, the Court of Appeals rendered a Decision dated June 19, 2019 reversing the RTC and declaring Sangguniang Panlungsod Resolution No. 1169, series of 2018 void for lack of jurisdiction. The CA concluded that Section 32 of JMC No. 2017-01 vested the Office of the President with exclusive authority to entertain complaints for disciplinary action, suspension, and removal against Pederasyon presidents in highly urbanized cities, and thus the Sangguniang Panlungsod acted without jurisdiction in removing an SK Federation president.

Court of Appeals Decision in CA-G.R. SP No. 162895

In CA-G.R. SP No. 162895, which concerned Carlos’s removal as SK Chairperson of Barangay Marulas, the Court of Appeals rendered a Decision dated June 30, 2020 affirming the RTC and upholding her removal. The CA held that R.A. No. 10742 was the special and more recent law governing the removal of SK officials, that the Sangguniang Panlungsod complied with its promulgated rules and the SK Reform Act, and that Carlos was afforded due process but chose not to participate in the administrative proceedings. The CA found that failure to formulate the Comprehensive Barangay Youth Development Plan and the Annual Barangay Youth Investment Program within the prescribed period constituted a valid ground for removal under Section 18(d) of R.A. No. 10742.

Consolidation and Reconciling of CA Rulings

The Court of Appeals consolidated the cases and, by Consolidated Resolution dated January 13, 2021, denied the respective motions for reconsideration. The CA reconciled its rulings by explaining that the mechanism for removing Pederasyon officers under JMC No. 2017-01 applied to Pederasyon officers as such, but the duties, suspension, and removal of elected SK officials were governed by R.A. No. 10742. Because the Pederasyon in a city was composed of SK chairpersons and elected its president from among them, the CA concluded that removal of an SK chairperson resulted in removal from the federation presidency.

Issues Presented to the Court

The Supreme Court identified the dispositive legal issues as whether: (1) the Sangguniang Panlungsod of a highly urbanized city may remove an SK Federation president from office; (2) the Sangguniang Panlungsod of a highly urbanized city may remove an SK chairperson from office without court intervention; and (3) removal from office of an SK chairperson by the Sangguniang Panlungsod also constitutes removal of the same officer as the SK Federation president.

Court’s Analysis on Jurisdiction Over SK Federation President

The Court examined Section 32 of JMC No. 2017-01, which prescribes that a verified complaint against any Pederasyon Officer shall be filed before the Office of the President in the case of Panlungsod Pederasyon Presidents who are ex-officio members of the Sangguniang Panlungsod of a highly urbanized city. Applying the plain-meaning rule, the Court held that jurisdiction to entertain complaints against a Pederasyon president of a highly urbanized city lay with the Office of the President. The Court concluded that the Sangguniang Panlungsod of Valenzuela City acted without jurisdiction in approving Resolution No. 1169, series of 2018, effecting the removal of Carlos as Pederasyon president and installing Carreon.

Court’s Analysis on Sangguniang Panlungsod Authority to Remove SK Chairperson

The Court reconciled the Local Government Code provision that an elective local official may be removed only by order of the proper court with the SK Reform Act. The Court noted that Congress included a repealing or modifying clause in R.A. No. 10742 to the extent of inconsistency with existing laws. The Court therefore held that insofar as SK officials are concerned, the provisions of Section 60, R.A. No. 7160 were superseded by the SK Reform Act. The Court relied on Section 18 of R.A. No. 10742, which authorizes any e

Case Syllabus (G.R. No. 255453)

Parties and Procedural Posture

Petitioners included the Sangguniang Panlungsod ng Valenzuela City and its named members together with SK Chairperson Chiqui Marie N. Carreon in her capacity as the installed federation president.
Respondent was SK Chairperson Pederasyon President Janine Alexandra R. Carlos in her capacity as SK Chairperson of Brgy. Marulas, SK Federation President, and ex-officio member of the Sangguniang Panlungsod.
The consolidated petitions for review under Rule 45, Rules of Court challenged the Court of Appeals Decisions dated June 19, 2019 and June 30, 2020 and its Consolidated Resolution dated January 13, 2021.
The Regional Trial Court earlier dismissed Carlos's certiorari petition for lack of jurisdiction in a Resolution dated February 18, 2019.
The Court of Appeals rendered conflicting rulings in separate dockets, later consolidated, and the Supreme Court received consolidated petitions for final review.

Key Factual Allegations

Janine Alexandra R. Carlos was elected SK Chairperson of Brgy. Marulas on May 22, 2018 and was elected president of the Valenzuela City Pederasyon ng mga SK thereafter.
The SK Federation alleged that Carlos was remiss in duties due to unjustified absences and uncooperative behavior that stalled federation projects and activities.
On September 29, 2018, thirty-one of thirty-three federation members approved installation of Chiqui Marie N. Carreon as federation president.
On October 1, 2018, the Sangguniang Panlungsod adopted Resolution No. 1169 series of 2018 recognizing Carreon's installation.
A separate administrative complaint was filed on October 16, 2018 by Enrico Mauhay and Reniel Montanez alleging Carlos failed to formulate the Comprehensive Barangay Youth Development Plan and the Annual Barangay Youth Investment Program as required under R.A. No. 10742.
The Sangguniang Panlungsod rendered a Decision dated January 21, 2019 removing Carlos from office as SK chairperson and declaring the removal final and executory.

Procedural History

Carlos filed a petition for certiorari in the Regional Trial Court challenging her removal as federation president for lack of due process and asserting the JMC No. 2017-01 required complaints to be filed with the Office of the President.
The RTC dismissed the certiorari petition for lack of jurisdiction and held that the remedy was an appeal to the Office of the President under JMC No. 2017-01.
In CA-G.R. SP No. 160131, the Court of Appeals reversed the RTC on June 19, 2019 and declared the Sangguniang Panlungsod Resolution No. 1169 void for lack of jurisdiction to remove a federation president.
In CA-G.R. SP No. 162895, the Court of Appeals on June 30, 2020 affirmed the RTC and upheld the removal of Carlos as SK chairperson for failure to perform statutory duties under R.A. No. 10742.
The Court of Appeals issued a Consolidated Resolution dated January 13, 2021 denying motions for reconsideration and consolidating the rulings.
The Supreme Court consolidated the appeals and resolved the legal conflicts in the present Decision.

Issues Presented

Whether the Sangguniang Panlungsod of a highly urbanized city may remove an SK Federation President from office.
Whether the Sangguniang Panlungsod of a highly urbanized city may remove an SK Chairperson from office without court intervention.
Whether removal of an SK Chairperson by the Sangguniang Panlungsod also effects the removal of the same officer as SK Federatio