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LIGA NG MGA BARANGAY NATIONAL v. CITY MAYOR OF MANILA

FACTS:

The case involves a petition for certiorari seeking the nullification of Manila City Ordinance No. 8039, Series of 2002, and respondent City Mayor's Executive Order No. 011, Series of 2002. The petitioner, Liga ng mga Barangay National, is the national organization of all barangays in the Philippines. The Liga adopted and ratified its own Constitution and By-laws, which govern its internal organization. The Liga also adopted and ratified its own Election Code. The City Council of Manila enacted Ordinance No. 8039, which provided for the election of representatives in the City Chapter of Manila and set the elections for both chapters thirty days after the barangay elections. The ordinance was transmitted to the City Mayor for his signature and approval. The Liga, upon being informed of the ordinance, sent a letter requesting the Mayor to veto it. However, the Mayor signed and approved the ordinance and issued an Executive Order to implement it. The Liga filed the instant petition, alleging grave abuse of discretion by the City Council and the City Mayor.

The case involves a petition filed by the Liga ng mga Barangay ng Pilipinas (Liga), challenging the validity of City Ordinance No. 8039, Series of 2002, and Executive Order No. 011, Series of 2002, of the Manila City Council. The Liga argues that these ordinances contradict the Liga Election Code and are therefore invalid. The petitioner also seeks a temporary restraining order to prevent the implementation of the ordinances. Barangay Chairman Arnel Peña filed a Complaint in Intervention supporting the Liga's position and seeking the nullification of the ordinances and the elections conducted pursuant to them. The Office of the Solicitor General (OSG) filed a Manifestation supporting the petition and arguing that the ordinances are inconsistent with the Local Government Code. The respondents defend the validity of the ordinances and argue for the dismissal of the petition on various grounds.

ISSUES:

  1. Whether certiorari under Rule 65 is the proper remedy in this case.

  2. Whether the petitioner has other available remedies.

  3. Whether the petitioner is guilty of forum shopping.

  4. Whether the acts sought to be enjoined are fait accompli.

  5. Whether or not the respondents fall within the ambit of tribunal, board, or officer exercising judicial or quasi-judicial functions.

  6. Whether or not the petition is a petition for certiorari or a petition for declaratory relief.

  7. Whether or not there is a clear disregard of the hierarchy of courts.

    • Whether forum-shopping exists in this case
    • Whether the requisites of litis pendentia are present

RULING:

  1. The Supreme Court dismissed the petition for certiorari.

  2. The respondents do not fall within the ambit of tribunal, board, or officer exercising judicial or quasi-judicial functions. Therefore, certiorari will not lie.

  3. The petition is considered as a petition for declaratory relief, which is outside the original jurisdiction of the Supreme Court.

  4. There is a clear disregard of the hierarchy of courts as the petition did not invoke any special and important reason or exceptional and compelling circumstance that would warrant direct recourse to the Supreme Court.

    • Forum-shopping does not exist in this case as the parties involved in this case and the alleged pending cases are different individuals or entities.
    • The requisites of litis pendentia are not present as there is no identity of parties and rights asserted in the other pending cases.

PRINCIPLES:

  • Certiorari under Rule 65 of the Rules of Court is only available against a tribunal, board, or officer exercising judicial or quasi-judicial functions.

  • Quasi-judicial function applies to the actions of public administrative officers or bodies required to investigate facts, hold hearings, and draw conclusions as a basis for their official action.

  • There must be no other appeal or any plain, speedy, and adequate remedy in the ordinary course of law for certiorari to be the proper remedy.

  • The petitioner cannot claim no other recourse when there are pending cases in other courts seeking similar relief.

  • The prohibition against forum-shopping applies when the parties represent the same interest.

  • A case becomes moot and academic when certain events or circumstances render the relief sought no longer possible or meaningful.

  • Before a tribunal, board, or officer may exercise judicial or quasi-judicial acts, there must be a law that gives rise to specific rights and a controversy brought before a tribunal with the power and authority to determine the law and adjudicate the rights.

  • The Supreme Court has only appellate jurisdiction over petitions for declaratory relief.

  • The Supreme Court's original jurisdiction to issue a writ of certiorari is not exclusive and is concurrent with the Regional Trial Courts and the Court of Appeals.

  • There is a hierarchy of courts, and petitions for extraordinary writs should be filed with the appropriate court according to the hierarchy, unless there are exceptional and compelling reasons justifying direct recourse to the Supreme Court.

  • The policy of following the hierarchy of courts is necessary to prevent inordinate demands on the Supreme Court's time and attention and to prevent further overcrowding of its docket.

  • Forum-shopping exists when the elements of litis pendentia are present or when a final judgment in one case will amount to res judicata in the other.

  • The requisites of litis pendentia are: (1) identity of parties or parties representing the same interests, (2) identity of rights asserted and reliefs prayed for, and (3) identity with respect to the first two requisites, such that any judgment in one case will amount to res judicata in the other case.