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Overview, Local Governments as part of the Executive Branch  That they disregard any pronouncement issued by David on all

pronouncement issued by David on all matters relating to


GR No. 152774 – National Liga ng mga Barangay v. Paredes the affairs of the Liga
Tinga, J. 7. Later, public respondent Judge Victoria Paredes issued the assailed order which
granted the Urgent Motion of the DILG for appointment as interim caretaker of
The Respondent Judge Paredes issued an order granting the DILG’s request to be declared the Liga.
interim caretaker of the National Liga ng mga Barangay. Pursuant to this designation, it 8. David filed an urgent motion for the reconsideration of the assailed order, claiming that
disregarded the Liga’s bylaws and conducted its elections and appointed certain officials. it divested the duly elected members of the Board of Directors of the Liga National of
The Court ruled that this order and the acts arising from it are a derogation of the their positions without due process. He also sought to declare Secretary Barbers in
Constitution, as the power exercised by the President over local government units contempt of court for the issuance of the Memorandum (Fact #7) pending action by the
contemplates only supervision and not control. Court on its Urgent Motion.
9. The DILG later issued a Certificate of Appointment in favor of Rayos as president of the
Liga Caloocan. It also conducted the elections of Provincial and Metropolitan Liga
DOCTRINE Chapters. Thereafter, the National Liga also held its election of officers, wherein James
As the entity exercising supervision over the Liga ng mga Barangay, the DILGs authority Lim was elected as president of the National Liga.
over the Liga is limited to seeing to it that the rules are followed, but it cannot lay down such 10. Later, Judge Paredes denied David’s MR (Fact #9). Petitioners then filed the instant
rules itself, nor does it have the discretion to modify or replace them. petition for certiorari seeking to annul the respondent judge’s orders, claiming
that its designation of the DILG as interim caretaker and the acts which it sought
FACTS to implement pursuant to its designation as such are beyond the scope of the
1. Herein respondent Manuel Rayos, Punong Barangay of Barangay 52, District II, Zone Chief Executive’s power of supervision. Arguments:
5, Caloocan City, filed a petition for prohibition and mandamus and/or temporary  The power of general supervision of the President over LGU’s does not apply to
restraining order before the RTC of Caloocan. He alleged that herein petitioner Alex the Liga and its chapters becase the Liga is not an LGU.
David, Punong Barangay of another barangay in Caloocan and then president of the  The Judge’s orders divested the incumbent officers of the Liga of their right to
Liga ng Mga Barangay (National Chapter and Caloocan Chapter), committed certain their offices without due process.
irregularities in the notice, venue, and conduct of the proposed synchronized Liga ng  Even assuming that the Liga is an LGU, there is still no basis for the DILG to be
mga Barangay elections in 1997. These allegations consisted of: appointed as interim caretaker. The actions contemplated by the DILG go
 Publication of the notice in the Manila Bulletin but without notifying in writing the beyond supervision and what it sought to obtain was authority to alter, modify,
individual punong barangays of Caloocan; nullify, or set aside the actions of the Liga Board of Directors.
 The Notice of Meeting for the Liga Chapter of Caloocan did not clearly state the 11. Rayos argues that since the Secretary of DILG supervises the acts of local officials by
time (8 am or 8 pm) and was to be held in Lingayen, Pangasinan; ensuring that they act within the scope of their powers and functions, and since
 The deadline for filing of the Certificates of Candidacy was irregular (Rayos failed members of various leagues such as the Liga in this case are themselves officials of
to meet the said deadline). LGU’s, it follows that the Liga members are subject to the power of supervision of the
2. The executive Judge issued a TRO enjoining the holding of the election. However, as DILG.
the TRO was not properly served on David, the election of the officers for the Caloocan
Chapter was conducted, and David was proclaimed President of the Liga Caloocan. He ISSUE with HOLDING
thus took his oath and assumed the position. W/N the DILG’s caretakership of the Liga and the official acts of the DILG as such
3. Respondent Rayos filed a second petition, this time for quo warranto, mandamus, and caretaker exceeded the bounds of supervision – YES
prohibition against David, Nancy Quimpo (Presiding Officer of the Sangguniang  The Liga ng mga Barangay is the organization of all barangays, the primary
Panlungsod of Caloocan), and DILG Secretary Barbers. Rayos claimed that he was purpose of which is the determination of the representation of the Liga in the
elected president of the Caloocan Chapter. sanggunians. It is primarily governed by the provisions of the LGU; however, they
4. The DILG, through respondent Secretary Barbers, filed an Urgent Motion, are empowered to make their own constitution and by-laws to govern their
invoking the President’s power of general supervision over all local government operations (Sec. 507).
units. He sought that the DILG, pursuant to its delegated power of general  Sec. 4 Art. X of the Constitution reads in part, “The president of the
supervision, be appointed as the Interim Caretaker to manage and administer the Philippines shall exercise general supervision over local governments.”
affairs of the Liga until a new set of National Legal Officers had been elected. o The Court has defined supervision as overseeing that subordinate
5. David opposed this motion, claiming that the DILG’s request to be appointed as interim officers perform their duties and to take such action as prescribed by law
caretaker constitutes undue interference in the internal affairs of the Liga, since the Liga to compel his subordinates to perform their duties. Control means the
is not subject to DILG control and supervision. power of an officer to alter or modify or set aside what a subordinate
6. Before the lower court can act upon the Urgent Motion, DILG issued a Memorandum officer had done in the performance of his duties.
Circular to all provincial governors, vice governors, city mayors and vice mayors, o Supervisory power, when contrasted with control, is the power of
members of the sangguniang panlalawigan and panlungsod. The Memorandum mere oversight over an inferior body and does not include any
directed: restraining authority over such body.
 That the concerned not recognize any Liga Presidents as members of the o Supervisory power as defined in the case of Drilon v. Lim: “The
sanggunian supervisor or superintendent merely sees to it that the rules are followed,
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but he himself does not lay down such rules, nor does he have the
discretion to modify or replace them. If the rules are not observed, he
may order the work done or re-done but only to conform to the prescribed
rules. He may not prescribe his own manner for the doing of the act. He
has no judgment on this matter except to see that the rules are followed.”
 The Liga ng mga Barangay is subject to the president’s power of general
supervision, as exercised by the DILG Secretary as his alter ego. It was ruled in
Bito-Onon v. Fernandez that the liga is a government organization, being an
association, federation, league, or union created by law, whose members are
either appointed or elected government officials. (The representatives of the Liga
sit in an ex officio capacity in the sanggunians.)
 The Judge’s order appointing the DILG as interim caretaker effectively removed
the management of the LIga from the National Liga Board and vested control on
the DILG. The DILG was seeking management and control of the affairs of the Liga
until a new set of officers have been elected. Such conferment of control is in
derogation of the Constitution.
 The acts of the DILG went beyond the sphere of general supervision and
constituted direct interference with the political affairs, not only of the Liga, but
more importantly, of the barangay as an institution. The election of Liga officers is
part of the Ligas internal organization, for which the latter has already provided
guidelines. In succession, the DILG assumed stewardship and jurisdiction over the
Liga affairs, issued supplemental guidelines for the election, and nullified the
effects of the Liga-conducted elections. Clearly, what the DILG wielded was the
power of control which even the President does not have.
 As the entity exercising supervision over the Liga ng mga Barangay, the
DILGs authority over the Liga is limited to seeing to it that the rules are
followed, but it cannot lay down such rules itself, nor does it have the
discretion to modify or replace them.

DISPOSITIVE PORTION
WHEREFORE, the Petition is GRANTED. The Order of the Regional Trial Court dated 04
August 1997 is SET ASIDE for having been issued with grave abuse of discretion amounting
to lack or excess of jurisdiction. DILG Memorandum Circulars No. 97-176 and No. 97-193,
are declared VOID for being unconstitutional and ultra vires. No pronouncements as to costs.
SO ORDERED.

DIGESTER: Alyssa Mateo

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