Sanciangco v. Roño
REITERATIONFacts
The Antecedents: Petitioner Napoleon E. Sanciangco was elected Barangay Captain and subsequently became President of the Association of Barangay Councils (ABC) of Ozamiz City. By virtue of this position, he was appointed as a member of the Sangguniang Panlungsod of Ozamiz City. Procedural History: On March 27, 1984, petitioner filed his Certificate of Candidacy for the May 14, 1984 Batasan Pambansa elections. After his unsuccessful bid, he sought to resume his duties as a member of the Sangguniang Panlungsod, invoking Section 13(2) of Batas Pambansa Blg. 697. Respondent Minister of Local Government Jose A. Rono ruled that as an appointive official, petitioner was deemed to have resigned upon filing his Certificate of Candidacy. The Petition: Petitioner impugns the ruling, arguing that Section 13(2) of Batas Pambansa Blg. 697 makes no distinction between elective and appointive officials, and that legislative intent clearly covers appointive officials.
Issue(s)
Whether an appointive member of the Sangguniang Panlungsod who ran for the position of Mambabatas Pambansa should be considered as resigned or on forced leave of absence upon filing his Certificate of Candidacy. Whether Section 13(2) of Batas Pambansa Blg. 697, which refers to "members of the various sanggunians," applies to both elective and appointive members.
Ruling
The Supreme Court denied the petition, finding no grave abuse of discretion on the part of the respondent officials. The Court ruled that the petitioner, as an appointive member of the Sangguniang Panlungsod, ipso facto ceased to be such member upon filing his certificate of candidacy.
Ratio Decidendi
On the issue of whether an appointive member of the Sangguniang Panlungsod who filed a certificate of candidacy should be considered resigned or on forced leave: The Court held that the petitioner, being an appointive member of the Sangguniang Panlungsod, ipso facto ceased to be such member as of the time he filed his certificate of candidacy for the Batasan Pambansa elections. This is in contrast to elective local officials who are considered on forced leave of absence under Section 13(2) of Batas Pambansa Blg. 697. The Court distinguished between Section 13(1), which covers "any person holding a public appointive office or position," and Section 13(2), which enumerates "Governors, mayors, members of the various sanggunians or barangay officials." The legislative intent, as gleaned from the proceedings of the Batasan Pambansa, was to treat appointive officials under Section 13(1) and elective officials under Section 13(2). The Court emphasized that statutory construction requires considering the whole statute and every part thereof to fix the meaning of any of its parts, giving effect to the evident purpose and object sought to be attained by the enactment as a whole. The distinction between appointive and elective positions was deemed clear, with appointive officials ceasing ipso facto in office while elective officials are on forced leave. On the issue of whether Section 13(2) of Batas Pambansa Blg. 697 applies to both elective and appointive members of the sanggunian: The Court clarified that while Section 13(2) mentions "members of the various sanggunians," the legislative intent, when read in conjunction with Section 13(1) and the legislative records, is that Section 13(1) applies to all appointive officials, including appointive sanggunian members, who cease ipso facto in office. Section 13(2) specifically pertains to elective local officials. The Court cited the exchange during the Batasan Pambansa proceedings where it was clarified that appointive local officials fall under paragraph (1), while elective local officials fall under paragraph (2). Therefore, the petitioner, as an appointive member, is governed by the provisions of Section 13(1), not Section 13(2). The Court also found no violation of the equal protection clause, as the law applies to all persons under like circumstances, and the consequence of running for office arose from law due to the petitioner's own choice.
Main Doctrine
An appointive member of the Sangguniang Panlungsod who files a certificate of candidacy for a national elective position is deemed to have ipso facto ceased in office, as distinguished from elective local officials who are considered on forced leave of absence upon filing their certificate of candidacy, pursuant to Batas Pambansa Blg. 697.