David v.

COMELEC
FACTS: David, brgy chairman from Kalookan and president of Liga ng mga Barangay
sa Pilipinas, sought to prohibit the holding of barangay elections scheduled on the
second Monday of May 1997.
On the other hand, Liga ng mga Barangay QC Chapter sought judicial review to declare
as unconstitutional certain laws including Sec 43 of the LGC, COMELEC resolutions,
and budget appropriations for elections, which all essentially limited the term of
barangay officials to three (3) years.
Sec. 1 of RA 6679 provides that the term of barangay officials who were to be
elected on the second Monday of May 1994 is 5 years
The later act RA 7160 Sec 43 (c) states that the term of office of barangay
officials who were to be elected also on the 2nd Monday of May 1994 is 3 years.
ISSUE: Which of the laws shall prevail?
RULING: LGC of 1991 was enacted later than RA 6679. It is basic that in case of
irreconcilable conflict between 2 laws, the later enactment prevails.
Later law repeals earlier one because it is the later legislative will. Section 43 of the
LGC reduced the term of barangay officials to 3 years which was clearly inconsistent
with RA 6679.
Congress appropriated budget to cover the barangay elections and ordained that a
registration of voters must be held after the barangay elections of 1997. Hence, these
are clear and express contemporaneous statements of Congress that barangay officials
shall be elected on May 1997.
LGC is not a general law. It is a special law insofar as it governs the term of office of
barangay officials. Its repealing clause expressly repealed all laws, general or special,
repugnant to the Code