Limbona vs.

Mangelin
Held: Autonomy is either decentralization of
GR No. 80391 28 February 1989
administration or decentralization of power.
There is decentralization of administration
when the central government delegates
Facts: Petitioner, Sultan Alimbusar Limbona,
administrative powers to political subdivisions
was elected Speaker of the Regional Legislative
in order to broaden the base of government
Assembly or Batasang Pampook of Central
power and in the process to make local
Mindanao (Assembly). On October 21, 1987
governments "more responsive and
Congressman Datu Guimid Matalam, Chairman
accountable". At the same time, it relieves the
of the Committee on Muslim Affairs of the
central government of the burden of managing
House of Representatives, invited petitioner in
local affairs and enables it to concentrate on
his capacity as Speaker of the Assembly of
national concerns. The President exercises
Region XII in a consultation/dialogue with local
"general supervision" over them, but only to
government officials. Petitioner accepted the
"ensure that local affairs are administered
invitation and informed the Assembly members
according to law." He has no control over their
through the Assembly Secretary that there shall
acts in the sense that he can substitute their
be no session in November as his presence was
judgments with his own. Decentralization of
needed in the house committee hearing of
power, on the other hand, involves an
Congress. However, on November 2, 1987, the
abdication of political power in the favor of
Assembly held a session in defiance of the
local governments units declared to be
Limbona's advice, where he was unseated from
autonomous. In that case, the autonomous
his position. Petitioner prays that the session's
government is free to chart its own destiny and
proceedings be declared null and void and be it
shape its future with minimum intervention
declared that he was still the Speaker of the
from central authorities.
Assembly. Pending further proceedings of the
case, the SC received a resolution from the
An autonomous government that enjoys
Assembly expressly expelling petitioner's
autonomy of the latter category [CONST.
membership therefrom. Respondents argue
(1987), Art. X, Sec. 15.] is subject alone to the
that petitioner had "filed a case before the
decree of the organic act creating it and
Supreme Court against some members of the
accepted principles on the effects and limits of
Assembly on a question which should have
"autonomy." On the other hand, an
been resolved within the confines of the
autonomous government of the former class is,
Assembly," for which the respondents now
as we noted, under the supervision of the
submit that the petition had become "moot and
national government acting through the
academic" because its resolution. 
President (and the Department of Local
Government). If the Sangguniang Pampook (of
Issue: Whether or not the courts of law have
Region XII), then, is autonomous in the latter
jurisdiction over the autonomous governments
sense, its acts are, debatably beyond the
or regions. What is the extent of self-
domain of this Court in perhaps the same way
government given to the autonomous
that the internal acts, say, of the Congress of
governments of Region XII? YES
the Philippines are beyond our jurisdiction. But not be called, it does not appear that the
if it is autonomous in the former category only, respondents called his attention to this mistake.
it comes unarguably under our jurisdiction. An What appears is that instead, they opened the
examination of the very Presidential Decree sessions themselves behind his back in an
creating the autonomous governments of apparent act of mutiny. Under the
Mindanao persuades us that they were never circumstances, we find equity on his side. For
meant to exercise autonomy in the second this reason, we uphold the "recess" called on
sense (decentralization of power). PD No. the ground of good faith. 
1618, in the first place, mandates that "[t]he
President shall have the power of general
supervision and control over Autonomous
Regions." Hence, we assume jurisdiction. And if
we can make an inquiry in the validity of the
expulsion in question, with more reason can we
review the petitioner's removal as Speaker. 

This case involves the application of a most 

important constitutional policy and principle,
that of local autonomy. We have to obey the
clear mandate on local autonomy. 

Where a law is capable of two interpretations,

one in favor of centralized power in Malacañang
and the other beneficial to local autonomy, the
scales must be weighed in favor of autonomy.

Upon the facts presented, we hold that the

November 2 and 5, 1987 sessions were invalid.
It is true that under Section 31 of the Region XII
Sanggunian Rules, " sessions shall not be
suspended or adjourned except by direction of
the Sangguniang Pampook". But while this
opinion is in accord with the respondents' own,
we still invalidate the twin sessions in question,
since at the time the petitioner called the
"recess," it was not a settled matter whether or
not he could do so. In the second place, the
invitation tendered by the Committee on
Muslim Affairs of the House of Representatives
provided a plausible reason for the intermission
sought. Also, assuming that a valid recess could