Limbona vs Mangelin

G.R. No. 80391

February 28, 1989
Facts:
Limbona was elected Speaker of the Regional Assembly of Central Mindanao. On
October 21, 1987, Congressman Matalam invited Limbona in a
consultation/dialogue with local government officials. Limbona accepted the
invitation and informed the Assembly Members through the Assembly Secretary
that there shall be no session in November as his presence was needed in the
House Committee hearing of Congress.
However, the Assembly held a meeting on November 2, 1987, and unseated
Limbona from his position. Limbona prays for the session to be declared null and
void and that he still be declared Speaker of the Regional Assembly.

Pending the case, the SC also received a resolution from the Assembly expelling
Limbonas membership.

Issues:

What is the extent of self-government given to the autonomous regions of

Region XII?

Held:
Yes.

Autonomy is either decentralization of administration or decentralization of

power.
Decentralization of Administration is the delegation by the central
government of administrative powers to political subdivisions in order
to broaden the base of government power and, in the process, to make
local governments more responsive and accountable and ensure their
development as self-reliant communities and make them more effective
partners in the pursuit of national development and progress.
It also relieves the central government of the burden of managing local affairs
and enables it to concentrate on national concerns. An autonomous government
under this category is under the supervision of the national government
through the President. The President exercises supervision but has no
control over them and does so only to ensure local affairs are administered
according to law.
Decentralization of Power, on the other hand, involves the abdication of
power in favor of autonomous local governments. The autonomous
government is free to manage its affairs with minimum intervention from
central authorities. An autonomous government enjoying autonomy under this
category is only subject to the organic act creating it and accepted
principles on the effects & limits of autonomy.
PD 1618 mandates that the President shall have the power of general
supervision and control over autonomous regions. Hence, courts of law can
assume jurisdiction. The courts can validly review the removal of Limbona as
Speaker.
Where a law is capable of 2 interpretations, one in favor of centralized power
in Malacaang and the other beneficial to local autonomy, the scales must be
weighed in favor of autonomy.
Under Sec. 31 of Region XII Sanggunian Rules, sessions shall not be suspended
or adjourned except by direction of the Sangguniang Pampook.

However, the November 2 and 5, 1987 sessions are declared invalid since at the
time Limbona called the recess, it was not a settled matter whether or not he
could do so. Secondly, the invitation by the House of Representatives
Committee on Muslim Affairs provides a plausible reason for the intermission
sought. Also, assuming that a valid recess could not be called, it does not
appear that respondents called his attention to his mistake. What appears is
they opened the sessions themselves behind his back in an apparent act of
mutiny. Under these circumstances, equity is on his side. The recess was
called on the ground of good faith.