Municipal Council of Lemery, Batangas v. Provincial Board of Batangas
REITERATIONFacts
1. The Antecedents: The Municipal Council of Lemery, Batangas, passed Resolution No. 18, series of 1931, consolidating the position of porter for the justice of the peace court with that of the messenger for the municipal president and municipal secretary, citing economy as the primary reason. This resolution aimed to reduce costs by having one individual perform the duties for all three offices, with a slight increase in salary for the consolidated role. 2. Procedural History: The Municipal Council of Lemery's Resolution No. 18 was submitted to the Provincial Board of Batangas, which disapproved it via Resolution No. 289, citing the need for adequate janitor service for the justice of the peace and the confidence required in such personnel. The Municipal Council appealed this disapproval to the Chief of the Executive Bureau, who ruled against the appeal. Following a denial of reconsideration, the Provincial Governor of Batangas issued a communication demanding compliance with the Provincial Board's order within twenty days, threatening administrative action against the council members. This led the Municipal Council to file the present action. 3. The Petition: The Municipal Council of Lemery filed a petition, which the Supreme Court determined to be a writ of certiorari, seeking to nullify Resolution No. 289 of the Provincial Board of Batangas. The petitioner argued that the Provincial Board exceeded its quasi-judicial powers by disapproving a resolution that was within the legislative authority of the Municipal Council. The petition also asserted that there was no plain, speedy, and adequate remedy available through administrative channels, as the Administrative Code does not permit an appeal from the Chief of the Executive Bureau's decisions to the Secretary of the Interior.
Issue(s)
Whether the proceedings of the provincial board in disapproving the municipal council's resolution were quasi-judicial in nature. Whether the provincial board exceeded its powers in disapproving the municipal council's resolution. Whether the municipal council had a plain, speedy, and adequate remedy in the administrative channels.
Ruling
The petition is granted. Resolution No. 289 of the Provincial Board of Batangas is declared null and void, and Resolution No. 18 of the Municipal Council of Lemery is held valid and lawful. The preliminary injunction is made permanent.
Ratio Decidendi
On the nature of the provincial board's function: The Court held that the provincial board's power to annul municipal resolutions or ordinances is quasi-judicial in nature. This is because the determination of whether an act is legal or not, as provided for in Section 2233 of the Administrative Code, is an essentially judicial function. The Court cited Corpus Juris and case law to define judicial and quasi-judicial acts, emphasizing that it is the nature of the act, not the office, that determines its classification. The provincial board, in reviewing the legality of the municipal council's resolution, exercises judgment and discretion to determine if the resolution is within the powers conferred by law. On whether the provincial board exceeded its powers: The Court ruled that the provincial board exceeded its quasi-judicial powers. Section 2233 of the Administrative Code limits the grounds for disapproval to resolutions being "beyond the powers conferred upon the council or president making the same." The provincial board's disapproval was based on the contention that the justice of the peace would not receive adequate porter service, which was a matter of sufficiency of service rather than the municipal council exceeding its powers. The Court clarified that while municipalities must provide janitor service (Section 212, Administrative Code), they have the legislative power to determine what service is necessary. The justice of the peace's recourse for inadequate service would be to demand proper service, not for the provincial board to nullify the resolution on grounds other than exceeding powers. On the availability of administrative remedies: The Court found that there was no plain, speedy, and adequate administrative remedy. Section 2235 of the Administrative Code only grants the right to appeal from provincial board decisions to the Chief of the Executive Bureau. The Administrative Code does not permit an appeal from the decisions of the Chief of the Executive Bureau to the Secretary of the Interior, thus limiting the available administrative recourse.
Main Doctrine
The power of a provincial board to disapprove a municipal resolution is a quasi-judicial function, and it may only do so if the resolution is beyond the powers conferred upon the municipal council. If the municipal council acts within its legislative powers, the provincial board exceeds its quasi-judicial powers in disapproving such resolution.