G.R. No. 127116 & G.R. No. 128039 April 8, 1997
Alex L. David, et al. vs. Commission on Elections, et al. / Liga ng mga Barangay Quezon City Chapter vs. Commission on Elections, et al.

FACTS

Petitioners, barangay officials elected in May 1994, sought to prohibit the Commission on Elections (COMELEC) from holding the barangay elections scheduled for May 12, 1997. They contended that their term of office was five years, not three, and thus the elections should be reset to 1999. Their claim was anchored on Republic Act No. 6679 , which provided for a five-year term for barangay officials beginning in 1989. They argued that this specific law was not repealed by the general provisions of the Local Government Code of 1991 (RA 7160), which set a three-year term for local officials including those in barangays. They further invoked Section 8, Article X of the Constitution , which prescribes a three-year term for local officials but states that the term for barangay officials “shall be determined by law,” suggesting a legislative intent to grant a different term.
The respondents, led by the COMELEC and the Solicitor General, maintained that the term was three years as expressly provided under Section 43(c) of RA 7160. They argued that the petitioners, having been elected under the rules and framework of the 1991 Local Government Code in 1994, were estopped from claiming a longer term while availing themselves of all the benefits and exercising powers granted solely by that same Code.

ISSUE

Whether the term of office of barangay officials elected in May 1994 is three years under RA 7160 or five years under RA 6679.

RULING

The Supreme Court ruled that the term is three years. The legal logic is grounded on the principle of implied repeal and the specific application of the later, comprehensive law. Republic Act No. 7160 , the Local Government Code, is a later, comprehensive statute that systematically governs all local government units. Section 43(c) explicitly states, “The term of office of barangay officials… shall be for three (3) years, which shall begin after the regular election… on the second Monday of May 1994.” This clear and categorical provision impliedly repealed the inconsistent five-year term provision in the earlier RA 6679. The Court emphasized that RA 7160 is a codified law intended to provide a uniform framework, and its specific clause governing the commencement of the term for the 1994 elections leaves no room for ambiguity.
Furthermore, the constitutional provision cited by petitioners does not support their claim. While Section 8, Article X of the Constitution delegates the determination of the barangay officials’ term to Congress, Congress exercised this power by enacting RA 7160 and fixing a three-year term. There is no constitutional prohibition against granting barangay officials the same three-year term as other local officials. The petitioners, having participated in the 1994 elections conducted under the authority and detailed regulations of the 1991 Code, are deemed to have accepted its terms, including the three-year tenure. Therefore, the COMELEC correctly scheduled the elections for May 1997, and the petitions were dismissed.