A3. Limbona v.

Mangelin
Facts:

 The autonomous governments of Mindanao were organized in Regions IX and XII by PD 1618. It
established, among other things, “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.

 PD 1618, however, mandates that “the President shall have the power of general supervision and
control over Autonomous Regions”, and authorizes the legislative arm to discharge only chiefly
administrative services.

 Petitioner Limbona was appointed as a member of the Sangguniang Pampook (Assembly) of Region
XII and was thereafter elected as Speaker of said Assembly.

 He was invited to participate in the consultation and dialogue with the Committee of Muslim Affairs of
the House of Representatives regarding the charting of the autonomous govts of Mindanao. Because of
said invitation, Limbona sent telegram to all Assemblymen that there will be no session during the time
that he will be in Congress.

 In defiance of Limbona, the Assembly held a session and declared the seat of the Speaker vacant.
Limbona thus filed this petition praying his speakership be declared valid and subsisting. Meanwhile,
the Assembly passed a resolution46 expelling Limbona from membership of the Sangguniang
Pampook. The jurisdiction of the courts to intervene in the affairs of the Sangguniang Pampook is being
challenged.

Issue. Considering the autonomous nature of the governments of Regions IX and XII, are these governments
subject to the jurisdiction of the national courts?

Held.
 Yes. Autonomy is either (1) decentralization of administration or (2) decentralization of power. A
government that enjoys autonomy in the latter is subject alone to the decree of the organic act creating
it and accepted principles on the effects and limits of “autonomy.”

 On the other hand, a government enjoying autonomy in the former is under the supervision of the
national government acting through the President (and the Dept of Local Govt).

 If the Sangguniang Pampook, then, is autonomous in the second sense, its acts are, debatably beyond
the domain of this Court in perhaps the same way that the internal acts, say, of the Congress of the
Philippines are beyond our jurisdiction.

 But if it is autonomous in the first sense only, it comes indisputably under our jurisdiction That PD 1618
mandates that “the President shall have the power of general supervision and control over Autonomous
Regions” and that it also authorizes the Sangguniang Pampook, their legislative arm, to discharge only
chiefly administrative services, persuades us that they were never meant to exercise autonomy in the
second sense.