Villa v. Llanes, Jr.
REITERATIONFacts
1. The Antecedents: Following the Barangay Elections of May 17, 1982, Demetrio G. Villa was proclaimed the winning candidate for barangay captain. A protest was filed by the opposing candidate, Concepcion M. Domingo, leading to a decision by the Laoag City Court on July 19, 1982, which declared Domingo as the winner. 2. Procedural History: The petitioner, Demetrio G. Villa, received the decision on July 20, 1982. He filed a notice of appeal and appeal bond on July 30, 1982, within ten days of receiving the decision. However, the Laoag City Court denied the appeal, citing Rule VII, Section 14 of COMELEC Resolution No. 1566, which stated that decisions in barangay election protests became final three days after receipt. 3. The Petition: This petition for certiorari and prohibition challenges the denial of the appeal. The petitioner argues that the appeal period should be governed by Batas Pambansa Blg. 222, the Barangay Election Act of 1982, which prescribes a ten-day period for appeals. The Supreme Court is asked to rule on the correct period for appeal and to set aside the denial of the petitioner's appeal.
Issue(s)
Whether the appeal filed by the petitioner was timely. Whether the respondent judge committed grave abuse of discretion in denying the appeal based on COMELEC Resolution No. 1566.
Ruling
The Supreme Court annulled and set aside the Order dated August 2, 1982, of the Laoag City Court. The respondent judge was directed to give due course to the petitioner's appeal.
Ratio Decidendi
On Issue 1: The appeal filed by the petitioner was timely. Section 20 of Batas Pambansa Blg. 222, the Barangay Election Act of 1982, explicitly provides that a decision in a barangay election protest may be appealed within ten (10) days from receipt of a copy thereof. The petitioner received the decision on July 20, 1982, and filed his notice of appeal and appeal bond on July 30, 1982, which was precisely the tenth day. Therefore, the appeal was filed within the statutory period. On Issue 2: The respondent judge committed grave abuse of discretion in denying the appeal. The judge relied on Rule VII, Section 14 of COMELEC Resolution No. 1566, which stated that decisions become final three days from receipt. However, this resolution was amended by COMELEC Resolution No. 1583 on June 22, 1982, which corrected the conflicting provision and stated that decisions become final after ten (10) days from receipt. More importantly, even without the amendment, Batas Pambansa Blg. 222, as a statute enacted by Congress, is superior to any implementing rule or resolution issued by an administrative body like the COMELEC. The COMELEC rule, which sought to shorten the appeal period to three days, was in direct conflict with the ten-day period provided by law and thus could not be validly applied.
Main Doctrine
The period for appeal in a barangay election protest is governed by Section 20 of Batas Pambansa Blg. 222, which prescribes a ten-day period from receipt of the decision. This statutory period prevails over any conflicting provision in COMELEC rules, such as the initial provision in COMELEC Resolution No. 1566 that declared decisions final three days after receipt. Even if COMELEC Resolution No. 1566 was amended by Resolution No. 1583 to align with the ten-day period, the statutory provision remains supreme and should have been applied correctly by the lower court.