Villafuerte v. Cordial
REITERATIONFacts
The Antecedents: Respondents, Mayor Constantino H. Cordial, Jr. and Vice-Mayor Irene R. Breis of Caramoan, Camarines Sur, were administratively charged with Grave Misconduct, Dishonesty, and Conduct Prejudicial to the Best Interest of Service. The complaint alleged that they, through the Sangguniang Bayan of Caramoan, passed Resolution No. 48 requesting the removal of Task Force Sagip Kalikasan without deliberation, following an inspection by the Task Force that discovered illegal mining activities and ordered a cessation of operations. Procedural History: The administrative complaint was filed before the Sangguniang Panlalawigan of Camarines Sur, which denied the respondents' Motion to Dismiss questioning its jurisdiction and the validity of its Rules of Procedure (Resolution No. 13-2013) due to alleged lack of publication. A subsequent Motion for Reconsideration was also denied, and the Sangguniang Panlalawigan recommended preventive suspension. The respondents then filed a petition for certiorari and prohibition with the Regional Trial Court (RTC). The RTC annulled the Sangguniang Panlalawigan's orders, ruling that the lack of publication of Resolution No. 13-2013 divested the Sangguniang Panlalawigan of jurisdiction, a decision subsequently challenged by the petitioners before the Supreme Court. The Petition: The petitioners assail the RTC's decision, arguing that the RTC erred in ruling that the non-publication of Resolution No. 13-2013 stripped the Sangguniang Panlalawigan of jurisdiction. They contend that Resolution No. 13-2013, being an internal procedural rule and not a penal or tax measure, did not require publication under the Local Government Code. Furthermore, they argue that jurisdiction is conferred by law based on the allegations in the complaint, and the RTC failed to distinguish between the requirement of publication for due process and the conferment of jurisdiction, raising a question of law regarding the necessity of publication for the effectivity of procedural rules of local sanggunians and its impact on jurisdiction.
Issue(s)
Whether the non-publication of Resolution No. 13-2013 divested the Sangguniang Panlalawigan of Camarines Sur of jurisdiction over the administrative proceedings against the respondents. Whether the respondents failed to exhaust administrative remedies.
Ruling
The Supreme Court granted the petition, reversed and set aside the decision and order of the RTC, and reinstated the orders and resolution of the Sangguniang Panlalawigan of Camarines Sur.
Ratio Decidendi
On the issue of jurisdiction and publication: The Court held that the non-publication of Resolution No. 13-2013 did not divest the Sangguniang Panlalawigan of jurisdiction. The Court clarified that while laws of general applicability and public nature require publication under Article 2 of the Civil Code, as expounded in Tañada v. Tuvera, Resolution No. 13-2013, being a rule of procedure for administrative cases against municipal officials, is interpretative and not of general applicability requiring publication. The Court emphasized that jurisdiction over the subject matter is conferred by law and is determined by the allegations in the complaint, citing Sections 61 and 62 of the Local Government Code (LGC) which grant the Sangguniang Panlalawigan jurisdiction over administrative complaints against erring municipal officials. The publication requirement is primarily for due process and the effectivity of laws, not a basis for conferring jurisdiction. Therefore, the RTC erred in concluding that the lack of publication stripped the Sangguniang Panlalawigan of its jurisdiction. On the issue of exhaustion of administrative remedies: The Court acknowledged that respondents failed to exhaust administrative remedies by not appealing to the Office of the President, as provided under the LGC. However, the Court found an exception to this rule because the question raised by the respondents before the RTC was purely legal in nature, concerning the jurisdiction of the Sangguniang Panlalawigan due to alleged lack of publication. The rule on exhaustion of administrative remedies generally requires parties to allow administrative agencies to resolve matters within their competence before resorting to judicial intervention. Nevertheless, when the issue is purely legal, direct resort to the courts, and in this instance, to the Supreme Court via a petition for review on certiorari, is permissible.
Main Doctrine
The non-publication of Resolution No. 13-2013, which provides the rules of procedure for administrative cases against municipal officials, does not divest the Sangguniang Panlalawigan of jurisdiction over such cases, as this resolution is interpretative and not of general applicability requiring publication under Article 2 of the Civil Code. Jurisdiction is conferred by law based on the allegations in the complaint, while publication is essential for due process and the effectivity of laws of general applicability.