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Sanciangco v.

Rono

Facts:
Napoleon Sanciangco was elected Barangay Captain of Barangay Sta.
Cruz, Ozamiz City, in the 17 May 1982 Barangay elections. Later, he was
elected President of the Association of Barangay Councils (ABC) of Ozamiz
City by the Board of Directors of the said Association. As the President of the
Association, Sanciangco was appointed by the President of the Philippines as
a member of the City’s Sangguniang Panlungsod. On 27 March 1984,
Sanciangco filed his Certificate of Candidacy for the 14 May 1984 Batasan
Pambansa elections for Misamis Occidental under the banner of the
Mindanao Alliance. He was not successful in the said election. Invoking
Section 13(2), Article 5 of BP 697, Sanciangco informed Vice-Mayor Benjamin
A. Fuentes, Presiding Officer of the Sangguniang Panlungsod, that he was
resuming his duties as member of that body. The matter was elevated to the
Minister of Local Government Jose A. Roño, who ruled that since Sanciangco
is an appointive official, he is deemed to have resigned from his appointive
position upon the filing of his Certificate of Candidacy.
The Supreme Court dismissed the petition and denied the writs prayed for,
holding that there was no grave abuse of discretion on the part of the
officials; without costs.

Issue:
Whether Local Government Minister Roño gravely abused its discretion
in ruling that Sanciangco is deemed to have resigned upon filing his COC

Held:
No. Sanciangco holds a public appointive position. He was appointed
by the President as a member of the City’s Sangguniang Panlungsod by
virtue of his having been elected President of the Association of Barangay
Councils. This was pursuant to Section 3, paragraph 1 of BP 51 (An Act
Providing for the elective or Appointive Positions in Various Local
Governments and for Other Purposes), and reiterated by Section 183 of the
Local Government Code (BP 337). Since Sanciangco is unquestionably an
appointive member of the Sangguniang Panlungsod of Ozamiz City, he is
deemed to have ipso facto ceased to be such member when he filed his
certificate of candidacy for the 14 May 1984 Batasan elections.
It is a rule of statutory construction that when the language of a
particular section of a statute admits of more than one construction, that
construction which gives effect to the evident purpose and object sought to
be attained by the enactment of the statute as a whole, must be followed. A
statute’s clauses and phrases should not be taken as detached and isolated
expressions, but the whole and every part thereof must be considered in
fixing the meaning of any of its parts. The legislative intent to cover public
appointive officials in subsection (1), and officials mentioned in subsection
(2) which should be construed to refer to local elective officials, can be
gleaned from the proceedings of the Batasan Pambansa.
There was no violation of the equal protection clause since Section 13
of BP 697 applies alike to all persons subject to such legislation under like
circumstances and conditions. Neither was the Sanciangco removed from
office without due process of law since it was of his own choice that he ran
for a seat in the Batasan Pambansa. The consequence that followed his
unsuccessful attempt at the elections arose from law. In the case at bar,
Sanciangco continues to be President of the Association of Barangay
Councils. He will need a reappointment by the President to be a part of the
Sangguniang Panglungsod of Ozamis City.

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