Liga ng mga Barangay National v. Atienza
REITERATIONFacts
The Antecedents: The Liga ng mga Barangay National (Liga), the national organization of barangays, operates under its own Constitution and By-laws and an Election Code, which govern its internal organization and the election of its officers. These rules were adopted in conformity with Republic Act No. 7160, the Local Government Code of 1991. The Liga's Election Code outlines a synchronized election process for its various chapters, including the Manila Chapter, with specific provisions for notification and the convening of chapter presidents and barangay chairmen for the purpose of reorganization and election. Procedural History: On June 28, 2002, the City Council of Manila enacted Ordinance No. 8039, which prescribed a different procedure for electing officers of the Liga's City Chapter and its District Chapters, setting the elections for thirty days after the barangay elections. This ordinance was approved by the City Mayor through Executive Order No. 011, Series of 2002. The Liga ng mga Barangay National, deeming these enactments to be an encroachment on its functions and contrary to law, filed a petition for certiorari with the Supreme Court. The Petition: The Liga ng mga Barangay National filed a petition for certiorari under Rule 65 of the Rules of Court, seeking to nullify Manila City Ordinance No. 8039 and Executive Order No. 011. The petitioner argued that these enactments were ultra vires acts of the respondents, as they usurped the Liga's prerogative to govern its own elections through its Constitution, By-laws, and Election Code, which were enacted in accordance with national law. The Liga contended that the City Council and City Mayor exceeded their legislative and executive powers, respectively, by legislating on the internal affairs of the Liga.
Issue(s)
Whether or not the respondent City Council of Manila committed grave abuse of discretion amounting to lack or excess of jurisdiction when it enacted City Ordinance No. 8039 S. 2002 to govern the elections of the Manila Chapter of the Liga ng mga Barangay, providing a different manner of electing its officers, despite the fact that said chapter's elections are mandated to be governed by the Liga Constitution and By-Laws and the Liga Election Code. Whether or not the respondent City Mayor of Manila committed grave abuse of discretion amounting to lack or excess of jurisdiction when he issued Executive Order No. 011 to implement the questioned City Ordinance No. 8039 S. 2002. Whether or not a petition for certiorari under Rule 65 is the proper remedy against the enactment of a city ordinance and the issuance of an executive order; and whether or not the Supreme Court has original jurisdiction over a petition seeking the declaration of unconstitutionality or illegality of a city ordinance and an executive order. Whether or not the petition violates the hierarchy of courts rule. Whether or not the issue of injunctive relief is moot and academic; and whether or not the petitioner is guilty of forum shopping.
Ruling
The petition is DISMISSED.
Ratio Decidendi
On the alleged grave abuse of discretion by the City Council: The enactment of Ordinance No. 8039 by the City Council of Manila was an exercise of legislative function, and the issuance of Executive Order No. 011 by the City Mayor was an exercise of executive function. Neither of these functions are judicial or quasi-judicial in nature. Therefore, certiorari will not lie against the respondents. On the alleged grave abuse of discretion by the City Mayor: The enactment of Ordinance No. 8039 by the City Council of Manila was an exercise of legislative function, and the issuance of Executive Order No. 011 by the City Mayor was an exercise of executive function. Neither of these functions are judicial or quasi-judicial in nature. Therefore, certiorari will not lie against the respondents. On the propriety of certiorari and the Supreme Court's original jurisdiction: The Supreme Court held that a petition for certiorari under Rule 65 is not the proper remedy in this case. The Court reiterated that certiorari lies only against a tribunal, board, or officer exercising judicial or quasi-judicial functions. The Court noted that while the petition was styled as one for certiorari, its essence was to seek the declaration of the unconstitutionality or illegality of the questioned ordinance and executive order. Such a petition partakes of the nature of a petition for declaratory relief, over which the Supreme Court has only appellate, not original, jurisdiction, as provided by Section 5, Article VIII of the Constitution. Thus, the petition must fail as the Supreme Court does not possess original jurisdiction over such matters. On the hierarchy of courts: Even if the petition were considered ripe for certiorari, the Court found a clear disregard of the hierarchy of courts. The Supreme Court's original jurisdiction to issue extraordinary writs is not exclusive but concurrent with the Regional Trial Courts and the Court of Appeals. Direct recourse to the Supreme Court should only be allowed when there are special and important reasons or exceptional and compelling circumstances, which were not sufficiently adduced by the petitioner or intervenor. The Court emphasized the policy of preventing demands on its time and preventing the overcrowding of its docket by requiring litigants to file petitions with the appropriate lower courts first. On the mootness of the issue and forum shopping: The respondents argued that the prayer for injunctive relief had become moot and academic because the elections of officers of the City Liga ng mga Barangay had already taken place and the officers had assumed their positions. The Court acknowledged that where events occurring during the pendency of a case render it moot and academic, the petition must be dismissed. The Court hesitated to rule that the petitioner was guilty of forum-shopping, noting that the respondents admitted that the parties in the instant petition and the alleged other pending cases were different individuals or entities and failed to furnish copies of the petitions filed in the lower courts, making it difficult to ascertain the exact causes of action and issues raised therein. Therefore, the essential requisites for litis pendentia, a component of forum-shopping, were not definitively established.
Main Doctrine
A petition for certiorari under Rule 65 of the Rules of Court is not the proper remedy against acts performed in the exercise of legislative or executive functions, as it is only applicable against tribunals, boards, or officers exercising judicial or quasi-judicial functions. Furthermore, direct recourse to the Supreme Court for extraordinary writs should only be allowed when there are special and important reasons or exceptional and compelling circumstances justifying such action, due to the established hierarchy of courts.