LIMBONA vs. MANGELIN Sarmiento, J.

(1989) FACTS Petitioner Limbona, a member of the Sangguniang Pampook, Regional Autonomous Government, Region XII (representing Lanao del Sur), was elected speaker of the Regional Legislative Assembly or Batasang Pampook of Central Mindanao (Assembly). Lambona as well as the Pampook Speaker of Region XI, Zamboanga City, were invited by the Chairman of the Committee on Muslim Affairs of the House of Representatives to attend conferences/consultations with local government officials, etc. to discuss present political developments and other issues affecting Regions IX and XII. Consistent with the invitation, Lambona sent telegrams to all Assemblymen informing them that there shall be no session in November as our presence in the house committee hearing of Congress take (sic) precedence over any pending business in Batasang Pampook. However, the Assembly still held sessions on Nov. 2, 1987 in defiance of Limbonas advice. In said sessions, the Assembly declared the seat of the Speaker vacant. Limbona went to Court praying that the proceedings held on the Nov. 2 session be declared null and void and that his election as Speaker be held valid and subsisting. Pending further proceedings, the Court received a Resolution filed by the Sangguniang Pampook expelling Limbona from membership therein. The resolution provided as ground for expulsion, Limbonas alleged acts of graft and corruption. ISSUES WON the so-called autonomous governments of Mindanao are subject to the jurisdiction of the national courts? HELD

The autonomous governments of Mindanao were organized in Regions IX and XII by PD 1618 promulgated on July 25, 1979. The Decree established internal autonomy in the two regions within the framework of the national sovereignty and territorial integrity of the Republic of the Philippines and its Constitution, with legislative and executive machinery to exercise the powers and responsibilities specified therein. It requires autonomous regional governments to undertake all internal administrative matters for the respective regions, except to act on matters which are within the jurisdiction and competence of the National Government. It also provides that the President shall have the power of general supervision and control over the Autonomous Regions. Autonomy is either decentralization of administration or decentralization of power. In decentralization of administration, the central government delegates administrative powers to political subdivision in order to broaden the base of government power and in the process to make local governments more responsive and accountable, and ensure their fullest development as self reliant communities and make them more effective partners in the pursuit of national development and social progress. Here, the autonomous government is under the supervision of the national government and the acts of the Sangguniang Pampook comes under SC jurisdiction. Decentralization of power, on the other hand, involves an abdication of political power in favor of local government units declared to be autonomous. Here, the autonomous government is free to chart its own destiny and shape its future with minimum intervention from central authorities. The autonomous government becomes accountable not to the central authority but to its constituency, amounting to self-immolation. In this case, the autonomous government is subject alone to the decree of the organic act creating it and accepted principles on the effects and limits of autonomy. In such case, the acts of the

YES. The autonomous regions enjoy autonomy in the sense of decentralization of administration and not decentralization of power; thus, they are subject to the supervision of the national government and are under the Supreme Court jurisdiction. RATIONALE

Sangguniang Pampook, are beyond the domain of the Supreme Court in the same way that the internal acts of Congress are beyond SC jurisdiction. PD 1618 mandates that the President shall have the power of general supervision and control over Autonomous Regions. Also, the Sangguniang Pampook, their legislative arm, is made to discharge chiefly administrative services. The Sanggunian is to exercise local legislative powers over regional affairs within the framework of national development plans, policies and goals. The Supreme Court therefore assumes jurisdiction. In resolving the case, the Court finds that the Nov. 2 and 5 sessions were invalid mainly on the principle of equity. Limbona is reinstated. Petition GRANTED.