Bito-onon v. Fernandez
REITERATIONFacts
The Antecedents: Petitioner Joel Bito-Onon was the elected Barangay Chairman and Municipal Liga Chapter President of Narra, Palawan, while private respondent Elegio Quejano, Jr. was the elected Barangay Chairman and Municipal Liga Chapter President of Magsaysay, Palawan. Both were candidates for Executive Vice-President of the Liga ng Barangay Provincial Chapter of Palawan. Bito-Onon won the election, and Quejano filed a post-proclamation protest with the Board of Election Supervisors (BES), which was decided against him. Procedural History: Quejano filed a Petition for Review of the BES decision with the Regional Trial Court (RTC). Bito-Onon filed a motion to dismiss, arguing that the RTC lacked jurisdiction because the DILG's Supplemental Guidelines (Memorandum Circular No. 97-193), which allowed review by regular courts, were an ultra vires act. The RTC denied the motion to dismiss, reasoning that the DILG Secretary had the power to issue such regulations under the Administrative Code. The RTC denied Bito-Onon's motion for reconsideration. The Petition: Bito-Onon filed a Petition for Certiorari and Prohibition with the Supreme Court, seeking to reverse the RTC's order denying his motion to dismiss. He raised issues of whether the DILG Secretary exceeded his authority in issuing the questioned provision and whether the RTC Judge committed grave abuse of discretion.
Issue(s)
Whether the questioned provision in Memorandum Circular 97-193 was issued by the DILG Secretary in excess of his authority. Whether the respondent Judge committed grave abuse of discretion in issuing the questioned orders.
Ruling
The Supreme Court granted the petition, reversed and set aside the Order of the Regional Trial Court dated June 22, 1999, and dismissed the Petition for Review filed by the private respondent.
Ratio Decidendi
On Issue 1 (Excess of Authority): The Court ruled that the DILG Secretary exceeded his authority. Memorandum Circular No. 97-193 allowed for a Petition for Review of the BES decision to be filed with the regular courts, which directly contradicted the Liga ng mga Barangay's own Guidelines. The Guidelines stipulated that decisions of the BES were subject to review by the National Liga Board, whose decision would be final and executory. By allowing an appeal to the regular courts, the DILG Secretary effectively amended the Liga's internal rules, which went beyond the scope of mere supervision and constituted an exercise of control. The power of supervision is limited to seeing to it that lower officers perform their functions in accordance with law, without the authority to alter or modify their actions. The DILG's role is to monitor compliance, not to dictate the internal organizational processes of the Liga. Therefore, the provision in Memorandum Circular No. 97-193 was an ultra vires act. On Issue 2 (Grave Abuse of Discretion): The Court found that the respondent Judge committed grave abuse of discretion amounting to lack or excess of jurisdiction. By denying the motion to dismiss and proceeding with the Petition for Review despite the lack of jurisdiction, the RTC Judge failed to recognize that the DILG Memorandum Circular was invalid and that the proper remedy was to exhaust administrative remedies within the Liga ng mga Barangay. The Liga ng mga Barangay, though a government organization, is not a local government unit in the strict sense that would subject it to the DILG's direct control over its internal organizational matters. The Court emphasized that any doubt regarding the DILG Secretary's power to interfere with local affairs should be resolved in favor of greater autonomy for the local government. Consequently, the RTC should have dismissed the petition for review for failure to exhaust administrative remedies and for lack of jurisdiction.
Main Doctrine
The Secretary of the Department of Interior and Local Government (DILG) exceeded his authority when he issued a Memorandum Circular allowing appeals from decisions of the Board of Election Supervisors (BES) to regular courts, as this constituted an exercise of control, not supervision, over the Liga ng mga Barangay, thereby violating the Liga's internal rules and the principle of local autonomy.