Limbona vs. Mangelin

CASE NO.: 6 Sec. 2. The territorial and political subdivisions shall enjoy local autonomy.
CASE TITLE: Limbona vs. Mangelin

TOPIC: Municipal Corporation: Types, Requisites, Creation xxxxxxxxxxxxxxxxx
AUTHOR: Dadivas
Sec. 15. There shall be created autonomous regions in Muslim Mindanao and
FACTS: in the Cordilleras consisting of provinces, cities, municipalities, and
geographical areas sharing common and distinctive historical and cultural
1. 08/24/1986: Sultan Alimbusar Limbona was appointed as a member of the heritage, economic and social structures, and other relevant characteristics
Sangguniang Pampook, Regional Autonomous Government, Region XII, representing within the framework of this Constitution and the national sovereignty as well
Lanao del Sur. Limbona was later elected Speaker of the Regional Legislative as territorial integrity of the Republic of the Philippines.
Assembly or Batasang Pampook of Central Mindanao (Assembly). The Assembly is
composed of 18 members.  An autonomous government that enjoys autonomy of the latter category [Art.
2. Two of said members, respondents Acmad Tomawis and Rakil Dagalangit, filed with X Sec. 15.] is subject alone to the decree of the organic act creating it and
the Comelec their respective certificates of candidacy in the May 11, 1987 accepted principles on the effects and limits of "autonomy." On the other hand,
congressional elections for the district of Lanao del Sur but they later withdrew from the an autonomous government of the former class is under the supervision of the
aforesaid election and thereafter resumed again their positions as members of the national government acting through the President (and the Department of
Assembly. Local Government).
3. Congressman Datu Matalam, Chairman of the Committee on Muslim Affairs of the  If the Sangguniang Pampook (of Region XII) is autonomous in the latter sense,
House of Representatives, invited Limbona in a letter, requested him to invite some its acts are beyond the domain of the Court in perhaps the same way that the
members of his Assembly to attend the House committee hearing for the discussion on internal acts of the Congress of the Philippines are beyond the Court’s
the proposed autonomy of Regions IX and XII. Consequently, Limbona sent a telegram jurisdiction. But if it is autonomous in the former category only, it comes
to Acting Secretary Johnny Alimbuyao of the Assembly to wire all Assemblymen that unarguably under the Court’s jurisdiction.
there shall be no session in November as "our presence in the house committee hearing  The autonomous governments of Mindanao were organized in Regions
of confess take precedence over any pending business in batasang pampook”. IX and XII by Presidential Decree No. 1618. An examination of the very
Limbona effectively called for a sessions recess lasting from November 1 through 15, Presidential Decree creating the autonomous governments of Mindanao
1987. concludes that they were never meant to exercise autonomy in the
4. 11/02/1987: the Assembly held session in defiance of petitioner's advice. After declaring second sense, that is, in which the central government commits an act
the presence of a quorum, the Speaker Pro-Tempore was authorized to preside in the of self-immolation. PD 1618, in the first place, mandates that "[t]he
session. On Motion to declare the seat of the Speaker vacant, all Assemblymen in President shall have the power of general supervision and control over
attendance voted in the affirmative, hence, the chair declared said seat of the Speaker Autonomous Regions." In the second place, the Sangguniang Pampook,
vacant. their legislative arm, is made to discharge chiefly administrative
5. 11/05/1987: the session of the Assembly resumed and the motion was again affirmed. services.
Limbona filed the present petition assailing the acts of the Assembly. Pending the  Hence, the court can assume jurisdiction.
proceedings, this Court received a resolution filed by the Sangguniang Pampook
"EXPELLING ALIMBUSAR P. LIMBONA FROM MEMBERSHIP OF THE NOTE: Did not include the decentralization of power and decentralization of
SANGGUNIANG PAMPOOK, AUTONOMOUS REGION XII," on the grounds, among administration anymore.
other things, that the petitioner "had caused to be prepared and signed by him paying
the salaries and emoluments of Odin Abdula, who was considered resigned after filing
his Certificate of Candidacy.. in the last May 11, elections and no request for
reinstatement by Abdula was ever made”. Such action constituted a usurpation of the
power of the Assembly.
ISSUE: Are the autonomous governments of Mindanao are subject to the jurisdiction of
the national courts?
RULING: YES!
Autonomy of LGUs under the 1987 Constitution
 Under the 1987 Constitution, local government units enjoy autonomy in these
two senses, thus:
Section 1. The territorial and political subdivisions of the Republic of the
Philippines are the provinces, cities, municipalities, and barangays. There
shall be autonomous regions in Muslim Mindanao and the Cordilleras as
hereinafter provided.

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CASE NO.: 6 Sec. 2. The territorial and political subdivisions shall enjoy local autonomy.

CASE TITLE: Limbona vs. Mangelin

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