Salva v. Makalintal
REITERATIONFacts
The Antecedents: Petitioners, officials and residents of barangay San Rafael, Calaca, Batangas, filed a class suit seeking the annulment of Ordinance No. 05 and Resolution No. 345, series of 1997, of the Sangguniang Panglalawigan of Batangas, and COMELEC Resolution No. 2987, series of 1998. Ordinance No. 05 declared the abolition of barangay San Rafael and its merger with barangay Dacanlao, instructing the COMELEC to conduct a plebiscite. Resolution No. 345 affirmed Ordinance No. 05, overriding the governor's veto. The governor's veto was based on the alleged failure to secure essential certifications from the Department of Finance, National Statistics Office, and Land Management Bureau. COMELEC Resolution No. 2987 provided rules for the plebiscite scheduled for February 28, 1998. Procedural History: Petitioners filed an ex parte motion for a temporary restraining order (TRO) and/or preliminary injunction before the Regional Trial Court (RTC) of Balayan, Batangas, Branch XI. The RTC denied the motion for lack of jurisdiction, ruling that any challenge to a COMELEC resolution must be brought before the Supreme Court. The Petition: Petitioners filed an instant petition for certiorari with the Supreme Court, seeking a TRO to enjoin the plebiscite, arguing that the RTC's denial encouraged multiplicity of suits and splitting of a cause of action. They contended that the RTC had jurisdiction over the validity of the ordinance and resolution, and consequently, over the COMELEC resolution which was merely incidental.
Issue(s)
Whether the Regional Trial Court has jurisdiction to enjoin the Commission on Elections from implementing its Resolution No. 2987, series of 1998, pending the determination of the validity of the underlying ordinance and resolution. Whether COMELEC Resolution No. 2987, calling for a plebiscite, is an act subject to the exclusive review of the Supreme Court via certiorari or an administrative act cognizable by the Regional Trial Court.
Ruling
The Supreme Court granted the petition, set aside the assailed RTC Order, and ordered the RTC to proceed with the case. The execution of the plebiscite results was ordered to be deferred pending the outcome of Civil Case No. 3442.
Ratio Decidendi
On the jurisdiction of the Regional Trial Court to enjoin COMELEC Resolution No. 2987: The Supreme Court held that the RTC's denial of the TRO was erroneous. The Court reasoned that the petitioners' suit before the RTC sought to annul Ordinance No. 05 and Resolution No. 345, which were the basis for COMELEC Resolution No. 2987. By filing the suit for annulment of the local ordinances, the RTC inherently had jurisdiction to pass upon the validity of the COMELEC resolution that was merely an incident of those ordinances. To require petitioners to seek a TRO from the Supreme Court for the COMELEC resolution, while simultaneously seeking annulment of the underlying ordinances from the RTC, would indeed lead to multiplicity of suits and splitting of a single cause of action, contrary to procedural rules. The Court emphasized that the RTC's jurisdiction over the primary issue of the validity of the local ordinances necessarily extended to the incidental COMELEC resolution. On whether COMELEC Resolution No. 2987 is subject to exclusive Supreme Court review: The Supreme Court clarified that Section 7, Article IX-A of the 1987 Constitution, which provides for certiorari to the Supreme Court for decisions, orders, or rulings of the COMELEC, applies only to its adjudicatory or quasi-judicial functions. The Court, citing Filipinas Engineering and Machine Shop v. Ferrer and Garces v. Court of Appeals, explained that administrative and ministerial acts of the COMELEC are not covered by this exclusive review. In this case, COMELEC Resolution No. 2987, which called for a plebiscite pursuant to Ordinance No. 05 and Resolution No. 345, was deemed a ministerial duty and part of the COMELEC's administrative functions. It involved no exercise of discretionary or adjudicatory power. Therefore, any question pertaining to its validity could be raised in an ordinary civil action before the trial courts, and not exclusively via certiorari to the Supreme Court. The cases cited by the COMELEC were distinguished as they pertained to the COMELEC's quasi-judicial powers.
Main Doctrine
A resolution of the Commission on Elections (COMELEC) calling for a plebiscite, issued pursuant to an ordinance and resolution of a local sanggunian and in accordance with statutory provisions, is considered an administrative function and not a quasi-judicial act. Therefore, challenges to such resolutions are cognizable by the Regional Trial Courts, and not exclusively by the Supreme Court via certiorari.