Sanciangco V. Rono

Sanciangco v. Rono Facts: Napoleon Sanciangco was elected Barangay Captain of Barangay Sta. Cruz, Ozamiz City, in the 17 May 1982 Barangay elections. Later, he was elected President of the Association of Barangay Councils (ABC) of Ozamiz City by the Board of Directors of the said Association. As the President of the Association, Sanciangco was appointed by the President of the Philippines as a member of the City’s Sangguniang Panlungsod. On 27 March 1984, Sanciangco filed his Certificate of Candidacy for the 14 May 1984 Batasan Pambansa elections for Misamis Occidental under the banner of the Mindanao Alliance. He was not successful in the said election. Invoking Section 13(2), Article 5 of BP 697, Sanciangco informed Vice-Mayor Benjamin A. Fuentes, Presiding Officer of the Sangguniang Panlungsod, that he was resuming his duties as member of that body. The matter was elevated to the Minister of Local Government Jose A. Roño, who ruled that since Sanciangco is an appointive official, he is deemed to have resigned from his appointive position upon the filing of his Certificate of Candidacy. The Supreme Court dismissed the petition and denied the writs prayed for, holding that there was no grave abuse of discretion on the part of the officials; without costs. Issue: Whether Local Government Minister Roño gravely abused its discretion in ruling that Sanciangco is deemed to have resigned upon filing his COC Held: No. Sanciangco holds a public appointive position. He was appointed by the President as a member of the City’s Sangguniang Panlungsod by virtue of his having been elected President of the Association of Barangay Councils. This was pursuant to Section 3, paragraph 1 of BP 51 (An Act Providing for the elective or Appointive Positions in Various Local Governments and for Other Purposes), and reiterated by Section 183 of the Local Government Code (BP 337). Since Sanciangco is unquestionably an appointive member of the Sangguniang Panlungsod of Ozamiz City, he is deemed to have ipso facto ceased to be such member when he filed his certificate of candidacy for the 14 May 1984 Batasan elections. It is a rule of statutory construction that when the language of a particular section of a statute admits of more than one construction, that construction which gives effect to the evident purpose and object sought to be attained by the enactment of the statute as a whole, must be followed. A statute’s clauses and phrases should not be taken as detached and isolated expressions, but the whole and every part thereof must be considered in fixing the meaning of any of its parts. The legislative intent to cover public appointive officials in subsection (1), and officials mentioned in subsection

(2) which should be construed to refer to local elective officials, can be gleaned from the proceedings of the Batasan Pambansa. There was no violation of the equal protection clause since Section 13 of BP 697 applies alike to all persons subject to such legislation under like circumstances and conditions. Neither was the Sanciangco removed from office without due process of law since it was of his own choice that he ran for a seat in the Batasan Pambansa. The consequence that followed his unsuccessful attempt at the elections arose from law. In the case at bar, Sanciangco continues to be President of the Association of Barangay Councils. He will need a reappointment by the President to be a part of the Sangguniang Panglungsod of Ozamis City.