Sangguniang Panlungsod v. Carlos
MODIFICATIONFacts
The Antecedents: Janine Alexandra R. Carlos, the Sangguniang Kabataan (SK) Chairperson of Brgy. Marulas and elected president of the SK Federation of Valenzuela City, faced allegations of dereliction of duty due to unjustified absences and uncooperative behavior, which hindered the SK Federation's projects and activities. Concurrently, an administrative complaint was filed against her for failing to submit the comprehensive barangay youth development plan and annual barangay youth investment program within the prescribed period, as required by Republic Act No. 10742 (SK Reform Act of 2015). Procedural History: The SK Federation, citing Carlos's alleged remissness, passed a resolution on September 29, 2018, installing Vice President Chiqui Marie N. Carreon as the new SK Federation President. The Sangguniang Panlungsod of Valenzuela City recognized this resolution. Carlos filed a petition for certiorari with the Regional Trial Court (RTC), arguing her removal lacked due process and that the SK Federation lacked the power to remove her without adhering to specific joint memorandum circulars. Separately, the Sangguniang Panlungsod, acting as a quasi-judicial body, removed Carlos from her position as SK Chairperson on January 21, 2019, for failing to formulate the required youth development plans. The RTC dismissed Carlos's petition for certiorari for lack of jurisdiction, stating the proper remedy was an appeal to the Office of the President. Carlos then appealed to the Court of Appeals (CA), which issued conflicting rulings: one declared the resolution removing her as SK Federation President void for want of jurisdiction, while the other affirmed her removal as SK Chairperson, holding that the SK Reform Act superseded the Local Government Code regarding removal procedures for SK officials. The Petition: Consolidated petitions for review on certiorari under Rule 45 of the Rules of Court were filed. The Sangguniang Panlungsod argued that the SK Reform Act and relevant joint memorandum circulars are silent on issues of leadership loss of trust and confidence within the SK Federation, granting them leeway to act. They contended they are not precluded from acknowledging actions determined by the Federation itself. Conversely, Carlos argued that the Sangguniang Panlungsod lacked the authority to remove an elected SK official, asserting that such removal must be through court intervention as per the Local Government Code, and that the SK Reform Act did not remove SK Chairpersons from this coverage. She also claimed the Sangguniang Panlungsod gravely abused its discretion by not considering her submitted development plans as substantial compliance.
Issue(s)
Whether the Sangguniang Panlungsod of a highly-urbanized city may remove an SK federation president from office. Whether the Sangguniang Panlungsod of a highly-urbanized city may remove an SK chairperson from office without court intervention. Whether the removal from office of an SK chairperson by the Sangguniang Panlungsod also constitutes the removal of the same officer as the SK federation president.
Ruling
The Supreme Court denied the consolidated petitions, affirming the Court of Appeals' resolution. It held that the Sangguniang Panlungsod of Valenzuela City acted without jurisdiction in removing Janine Alexandra R. Carlos as SK Federation President. However, her removal as SK Chairperson of Brgy. Marulas by the Sangguniang Panlungsod was valid under R.A. No. 10742. The Court further ruled that the removal of an SK Chairperson necessarily results in the removal of that individual as the SK Federation President. Consequently, Carlos' petition before the RTC challenging her removal as SK Federation President was rendered moot and academic by her valid removal as SK Chairperson.
Ratio Decidendi
On the removal of an SK Federation President: The Supreme Court ruled that the Sangguniang Panlungsod of Valenzuela City acted without jurisdiction in removing Carlos as SK Federation President. Section 32 of JMC No. 2017-01 clearly vests the Office of the President with jurisdiction over administrative complaints against SK Federation Presidents of highly urbanized cities. Therefore, the SP's Resolution No. 1169, series of 2018, which removed Carlos and installed Carreon, was void for want of jurisdiction. The Court emphasized that jurisdiction is conferred by law, and in this instance, the law clearly designated the OP as the proper body to handle such disciplinary actions. On the removal of an SK Chairperson: The Court held that the Sangguniang Panlungsod may remove an elected SK official based on the grounds enumerated in Section 18 of R.A. No. 10742. While Section 60 of the Local Government Code (LGC) previously mandated court intervention for the removal of elective local officials, R.A. No. 10742, as a special and more recent law, superseded the LGC provisions concerning SK officials. Section 18 of R.A. No. 10742 explicitly grants the Sangguniang Bayan or Sangguniang Panlungsod the power to remove SK officials by majority vote after due process. The Court found that the SP had jurisdiction over the administrative complaint against Carlos for failure to formulate the required youth development plans and investment programs, and that she was afforded due process. On the effect of SK Chairperson removal on SK Federation President position: The Supreme Court clarified that the removal of an SK Chairperson also results in the removal of that individual as the SK Federation President. Section 21 of R.A. No. 10742 states that the SK Federation is composed of the SK Chairpersons of the barangays in a city, and they elect a president from among themselves. Therefore, if an individual ceases to be an SK Chairperson, they can no longer hold the position of SK Federation President. Carlos remained SK Federation President only until her valid removal as SK Chairperson of Brgy. Marulas on January 21, 2019. After that date, she ceased to hold all three positions: SK Chairperson, SK Federation President, and ex-officio member of the Sangguniang Panlungsod.
Main Doctrine
The Sangguniang Panlungsod of a highly-urbanized city cannot remove an SK Federation President; such power rests with the Office of the President. However, the Sangguniang Panlungsod may remove an SK Chairperson based on grounds provided in R.A. No. 10742, and the removal of an SK Chairperson also results in the removal of the SK Federation President.