Fortuno v. Palma
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the qualification of Salvio B. Fortuno as a candidate for the Board of Directors of Camarines Sur II Electric Cooperative (CASURECO II), representing District V. Joel David S. Abante, another candidate, filed a petition alleging Fortuno was not a resident of the area, a requirement stipulated in the cooperative's By-laws and the Electric Cooperative Election Code. 2. Procedural History: Abante's disqualification petition was initially filed with the National Electrification Administration (NEA), which indorsed it to the CASURECO II District Election Committee (DEC). The DEC denied Abante's petition, finding Fortuno to be a resident. Fortuno was subsequently elected. Abante then filed a quo warranto petition in the Regional Trial Court (RTC) of Naga City, challenging Fortuno's qualification. The RTC upheld its jurisdiction, prompting Fortuno and CASURECO II to file the instant petition for certiorari and prohibition with the Supreme Court. 3. The Petition: Petitioners seek to annul the RTC's orders upholding its jurisdiction and enjoining Fortuno from assuming office. They argue that the DEC, vested with sole jurisdiction over election matters by the NEA-promulgated Electric Cooperative Election Code, had already ruled on Fortuno's residency, and its decision had become final. Petitioners contend that the RTC, by entertaining the quo warranto petition, is improperly interfering in the internal affairs of an electric cooperative and exceeding its jurisdiction, as the matter should have been exclusively resolved by the administrative bodies.
Issue(s)
Whether the Regional Trial Court has jurisdiction over quo warranto proceedings involving the qualification for membership of the Board of Directors of an electric cooperative. Whether the failure to exhaust administrative remedies bars a quo warranto suit. Whether the District Election Committee committed a grave abuse of discretion in denying the petition to disqualify Fortuno.
Ruling
The petition is DISMISSED. The Regional Trial Court has jurisdiction over the quo warranto proceedings. The restraining order issued by the RTC is maintained.
Ratio Decidendi
On the jurisdiction of the Regional Trial Court over quo warranto proceedings involving electric cooperatives: The Supreme Court affirmed that a quo warranto proceeding under Rule 66 of the Rules of Court is the proper action to determine the right to hold an office, including that of a director in a private corporation. The Court found no law exempting electric cooperatives from the coverage of quo warranto suits. It held that while the NEA has supervision and control over electric cooperatives, this does not deprive a party of the right to file a quo warranto suit, especially when there are allegations of grave abuse of discretion or lack of jurisdiction by the administrative body. The Court emphasized that CASURECO II is a duly organized private corporation, not an unincorporated association, making its proceedings subject to judicial review. On the failure to exhaust administrative remedies: The Court clarified that the rule on exhaustion of administrative remedies is not absolute. It stated that judicial intervention is permissible when there is an allegation of grave abuse of discretion, or when the administrative remedy is not adequate or would not afford sufficient time to address the issue, particularly in light of the impending assumption of office by the new Board of Directors. The Court noted that the RTC found the issue of qualification to be a justiciable controversy and that the forthcoming assumption of office by the new board would not allow sufficient time to pursue higher NEA authorities. On the alleged grave abuse of discretion by the District Election Committee: The Court acknowledged the allegation in the quo warranto petition that the DEC "arbitrarily denied petitioner's complaint for disqualification of respondent Fortuno." This allegation, coupled with the RTC's finding that the hearing of the preliminary injunction would not constitute undue interference, supported the RTC's exercise of jurisdiction. The Court reiterated its ruling in Lions Clubs International that judicial review is warranted where the action complained of is capricious, arbitrary, or unjustly discriminatory, which was alleged by the respondent Abante.
Main Doctrine
The Regional Trial Court has jurisdiction over quo warranto proceedings questioning the qualification of a director of an electric cooperative, even if administrative remedies were not fully exhausted, especially when there is an allegation of grave abuse of discretion by the administrative body.