Estoesta, Francis Benedict G.

January 22, 2020

LAW-154

CASE SUMMARIES

CASE: CARPIO v. EXEC.SECRETARY

FACTS: Carpio is questioning the constitutionality of RA 6975 which put the Philippine National
Police under the DILG.
ISSUE: W/N RA 6975 is constitutional
RULING: Yes, RA 6785 is merely an administrative realignment and will not usurp the power of
the NAPOLCOM.
DOCTRINE: Under the doctrine of qualified political agency, department secretaries are mere alter
egos of the President and their acts are the acts of the President.

CASE: MAGTAJAS v. PRYCE

FACTS: Cagayan De Oro City enacted Ordinances prohibiting PAGCOR from opening a Casino
in the city
ISSUE: W/N the gambling done by PAGCOR is included in prohibition of gambling under the
LGC.
RULING: No, what is prohibited in the LGC is illegal gambling; not gambling authorized by law
such as the ones done by PAGCOR.
DOCTRINE: In giving the local government units the power to prevent or suppress gambling and
other social problems, the Local Government Code has recognized the competence of
such communities to determine and adopt the measures best expected to promote the
general welfare of their inhabitants in line with the policies of the State.

CASE: DRILON v. LIM

FACTS: Secretary of Justice Drilon declared an ordinance (Manila Revenue Code) in Manila null
and void for non-compliance with the prescribed procedure in tax ordinances
ISSUE: W/N Sec. Drilon’ act of invalidating the ordinance was valid
RULING: Yes, Sec Drilon’s act was that of supervision and not control; he merely determined
whether or not Mayor Lim performed his duties in accordance with law.
DOCTRINE: Control is the power of an officer to alter, modify, or set aside what a subordinate officer
had one while supervision is the power of a superior officer to see if the lower officer
performs their functions in accordance with law.

CASE: JOSON v. EXEC. SECRETARY

FACTS: Governor Joson was placed under preventive suspended for 60 days for allegedly
barging inside the session hall of the Sangguniang Panlalawigan while being
accompanied by armed men since the members were against a law that would let the
province acquire a loan from PNB.
ISSUE: W/N the DILG has the power to suspend Joson.
RULING: Yes, while the DILG was the investigating authority under AO 23, it is still the President
who is the disciplining authority and there was no usurpation of power.
DOCTRINE: The power of the President over administrative disciplinary cases against elective local
officials is derived from his power of general supervision over local governments

CASE: PIMENTEL v. AGUIRRE

FACTS: AO 372 was issued which directed department to implement cost-cutting measures and
withheld 10% of the internal revenue allotment from LGUs.
ISSUE: W/N the President committed grave abuse of discretion in directing LGUs to implement
a 25% cost-reduction measures.
RULING: No, the government was not totally removed of its power over local governments;
municipal governments are still agents of the national government.
DOCTRINE: Supervision is the power to oversee and can only be taken upon a failure of duty
whereas Control is the power to substitute his will over a subordinate.

CASE: PROVINCE OF BATANGAS v. ROMULO

FACTS: The GAAs from 1999-2001 earmarked funds of the IRA for the LGUs but imposed
certain conditions before they were released.
ISSUE: W/N the GAA provisions run counter to the local autonomy of local governments
RULING: Yes, under the constitution, local governments shall have a just share in the national
taxes and under the LGC, such shares are to be automatically released and imposing
conditions violates the constitutional mandate.
DOCTRINE: Fiscal autonomy is part of local autonomy and gives LGUs the power to allocate their
resources depending on their priorities,

CASE: BATANGAS CATV v. CA

FACTS: Batangas CATV increased its rates and the Mayor threatened to cancel their permit.
ISSUE: W/N the City council had the power to control Batangas CATV’s rates.
RULING: No, the power to control rates is exclusively within the jurisdiction of the NTC.
DOCTRINE: Municipal ordinances are inferior and subordinate to the laws of the state and those in
conflict with it are deemed invalid.

CASE: NATIONAL LIGA v. PAREDES

FACTS: Alex David was elected as President of the National Liga ng mga barangay-Caloocan
chapter. despite a temporary restraining order since the TRO was not properly served,
and because of this the DILG was appointed the caretaker of the Liga ng mga Barangay
ISSUE: W/N the DILG could be appointed as caretaker.
RULING: No, the DILG effectively took control over the Liga when it became caretaker and went
beyond its power of supervision as it interfered with its affairs.
DOCTRINE: The authority of DILG over the Liga is limited to supervision or seeing to it that rules are
followed and not that of control or creating its own rules or modifying or replacing such
rules.

CASE: DIMASONGCOP v. DATUMANONG

FACTS: 2 laws both created an engineering district in ARRMM and now petitioners are assailing
both laws as they violate the autonomy of ARMM.
ISSUE: W/N the laws are constitutional
RULING: No, they are unconstitutional as they contravene decentralization in ARMM
DOCTRINE: Decentralization has two forms: Deconcentration which is the delegation of authority and
responsibility to regional and local authorities whereas devolution is the transfer of
powers and the performance of some functions to LGUs.

CASE: ACORD v. ZAMORA

FACTS: In the GAA of year 2000, there was a provision that allocated funds to an IRA under a
programmed fund and another IRA for unprogrammed funds. Petitioners assailed the
validity of these 2 provisions claiming that it violates local autonomy, and the
constitutional mandate that local governments shall have a just share in national taxes.
ISSUE: W/N the provisions in the GAA are valid.
RULING: No, they are unconstitutional as they are contrary to the mandate that local governments
shall have a just share in the national taxes, and that these be automatically released;
the ruling is the same in Province of Batangas v. Romulo.
DOCTRINE: Even Congress is not authorized by the Constitution to hinder or impede the automatic
release of the IRA.