David v. Commission on Elections
NEW DOCTRINEFacts
1. The Antecedents: The underlying dispute concerns the term of office for barangay officials elected in May 1994. Petitioners contend that their term is five years, as established by Republic Act No. 6679, and seek to postpone the scheduled May 1997 barangay elections to May 1999. This would effectively extend their current terms. 2. Procedural History: Petitioner Alex L. David, in his capacity as Barangay Chairman and President of the Liga ng mga Barangay sa Pilipinas, filed a petition for prohibition (G.R. No. 127116) seeking to halt the May 1997 barangay elections. Subsequently, the Liga ng mga Barangay Quezon City Chapter, represented by Bonifacio M. Rillon, filed a petition for certiorari (G.R. No. 128039) challenging the constitutionality of Section 43(c) of R.A. 7160, COMELEC Resolutions 2880 and 2887, and the appropriation for the 1997 elections. The Supreme Court consolidated these two cases due to their common issue. 3. The Petition: The petitions, filed under Rule 65 and Rule 64 of the Rules of Court respectively, argue that Republic Act No. 6679, which established a five-year term for barangay officials, was not repealed by the later Republic Act No. 7160 (Local Government Code). Petitioners assert that Section 43(c) of R.A. 7160, which sets a three-year term, is unconstitutional as applied to them, citing that the Constitution's exception for barangay officials implies a term longer than three years. They also challenge the COMELEC's resolutions setting the May 1997 elections and the appropriation for these elections as grave abuse of discretion and unconstitutional.
Issue(s)
Whether the term of office of barangay officials elected in May 1994 is governed by RA 7160 (three years) or RA 6679 (five years). Whether Section 43(c) of RA 7160, which shortened the term to three years, is constitutional. Whether the petitioners are estopped from claiming a term other than that provided under RA 7160.
Ruling
The petitions are DENIED for being completely devoid of merit. SO ORDERED.
Ratio Decidendi
On the issue of which law governs the term of office: The Court held that Republic Act No. 7160 (Local Government Code of 1991) governs the term of office of barangay officials elected in May 1994. RA 7160 was enacted later than RA 6679 and explicitly provided a three-year term for barangay officials, which was inconsistent with the five-year term provided in RA 6679. The principle of legis posteriores priores contrarias abrogant dictates that the later law prevails. Furthermore, the repealing clause of RA 7160 explicitly repealed all inconsistent general and special laws, including RA 6679. The Court also noted that the manner of electing barangay officials was altered by RA 7160, requiring a direct vote for the punong barangay, which was the practice during the May 1994 elections, unlike the method prescribed in RA 6679. On the constitutionality of the three-year term: The Court affirmed the constitutionality of Section 43(c) of RA 7160. Article X, Section 8 of the Constitution states that the term of elective local officials is three years, except for barangay officials whose term "shall be determined by law." This provision grants Congress the discretion to fix the term of barangay officials without specific limitations. The Court found no clear and unequivocal breach of the Constitution in setting a three-year term. The deliberations of the Constitutional Commission confirmed that the intent was to leave the determination of the barangay officials' term to law, and RA 7160 did so by setting it at three years. On the issue of estoppel: The Court ruled that the petitioners are estopped from claiming a term longer than three years. Petitioner Alex L. David, in his certificate of candidacy for the May 9, 1994 elections, swore that he was eligible for the office of punong barangay. The election results showed that he and other barangay chairmen were elected directly by the electorate, consistent with RA 7160, not RA 6679 which prescribed a different method of election. If petitioners' theory of a five-year term were correct, their election itself would have been illegal. Ignorance of the law does not excuse compliance, and their belated claim of ignorance regarding the governing law is unacceptable.
Main Doctrine
The term of office of barangay officials elected in May 1994 is three years, as provided by Republic Act No. 7160 (Local Government Code of 1991), which repealed Republic Act No. 6679. The constitutional provision allowing the term of barangay officials to be determined by law does not prohibit a three-year term, and officials elected under RA 7160 are estopped from claiming a longer term.