Castillo v. Villarama
REITERATIONFacts
The Antecedents: Petitioner Bienvenido A. Castillo, Municipal Mayor of Pulilan, was administratively charged with oppression and mal-administration by Provincial Governor Jose M. Villarama. The Governor issued an order of suspension against Castillo. Procedural History: The Provincial Board investigated the charges. The Board, by unanimous vote, set the hearing for June 2, 1965. The Governor was absent from this meeting, and the Vice-Governor presided. The Board reset the hearing for June 9, 1965. On June 9, the session hall was padlocked, but the Board proceeded with the hearing in another room. The complaining witness was absent, and the Board received petitioner's evidence. On the same day, the Board acquitted Castillo and ordered his reinstatement. The Petition: Respondent Governor refused to recognize the Board's decision and instructed the Vice-Mayor not to relinquish the office of Mayor. Petitioner filed a petition for prohibition to prevent the enforcement of the Governor's instruction. A preliminary injunction was issued. Subsequently, petitioner's preventive suspension expired due to the lapse of the thirty-day limit, and he attempted to reassume office, but the Vice-Mayor initially declined until the writ of injunction was issued.
Issue(s)
Whether the Provincial Governor may validly refuse to recognize the decision of the Provincial Board rendered in his absence. Whether the meetings and proceedings of the Provincial Board on June 2 and June 9, 1965, were valid despite the absence of the Provincial Governor and Vice-Governor. Whether the petitioner is entitled to reinstatement upon his acquittal by the Provincial Board.
Ruling
The petition for prohibition is granted, and the preliminary injunction is made permanent. The respondent Provincial Governor is ordered to recognize the decision of the Provincial Board acquitting petitioner Bienvenido A. Castillo and to allow his reinstatement as Municipal Mayor of Pulilan.
Ratio Decidendi
On whether the Provincial Governor may validly refuse to recognize the decision of the Provincial Board rendered in his absence: The Provincial Governor cannot validly refuse to recognize the decision of the Provincial Board. The law vests the power to investigate and decide administrative cases against municipal officials in the Provincial Board as a body. The performance of this duty cannot be frustrated by the absence, whether fortuitous or deliberate, of the Provincial Governor. The Board's decision, when rendered unanimously by its members constituting a quorum, is binding. On the validity of the meetings and proceedings of the Provincial Board on June 2 and June 9, 1965, despite the absence of the Provincial Governor and Vice-Governor: The meetings and proceedings were valid. Section 5 of Republic Act No. 2264 provides that the presence of three members of the Provincial Board constitutes a quorum. It also states that in the absence of the Governor, the vote of a majority of the members present shall constitute a binding act of the Board. The Governor's presence is not indispensable for the valid transaction of business. The Board can function legally even without the Governor and Vice-Governor, provided a quorum is present. On whether the petitioner is entitled to reinstatement upon his acquittal by the Provincial Board: The petitioner is entitled to immediate reinstatement. The law mandates that if the decision of the Provincial Board is one of exoneration and the official concerned is still under suspension, his reinstatement follows as a matter of course. Furthermore, the thirty-day limit for preventive suspension had expired, and the petitioner was entitled to be reinstated without prejudice to the continuation of the proceedings, if any.
Main Doctrine
The absence of the Provincial Governor does not invalidate the proceedings of the Provincial Board, especially when a quorum is present and the law provides for the procedure in case of the Governor's absence. Furthermore, upon acquittal, an administratively suspended official is entitled to immediate reinstatement, and the thirty-day limit for preventive suspension must be observed.