G.R. No. 139813 , January 31, 2001
Joel Bito-Onon, petitioner, vs. Hon. Judge Nelia Yap Fernandez, R.T.C. Br. 50 Puerto Princesa City and Palawan, and Elegio Quejano, Jr., respondents.

FACTS

Petitioner Joel Bito-Onon and private respondent Elegio Quejano, Jr., both elected Barangay Chairmen and Municipal Liga Chapter Presidents in Palawan, were candidates for Executive Vice-President of the Liga ng mga Barangay Provincial Chapter in the 1997 election. Bito-Onon was proclaimed the winner. Quejano filed a post-proclamation protest with the Board of Election Supervisors (BES), which was decided against him. Instead of appealing to the National Liga Board as prescribed by the Liga’s own Implementing Rules and Guidelines, Quejano filed a Petition for Review directly with the Regional Trial Court (RTC), relying on a provision in DILG Memorandum Circular No. 97-193 which allowed review of BES decisions by regular courts. Bito-Onon moved to dismiss the petition, arguing the RTC lacked jurisdiction because the DILG Circular, in allowing court review, unlawfully amended the Liga’s internal rules and constituted an exercise of control, not mere supervision.

ISSUE

Whether the respondent judge committed grave abuse of discretion in denying the motion to dismiss and assuming jurisdiction over the Petition for Review, based on a DILG Circular that allegedly amended the Liga’s internal election guidelines.

RULING

Yes, the respondent judge committed grave abuse of discretion. The Supreme Court granted the petition, reversing the RTC’s orders and dismissing Quejano’s Petition for Review. The legal logic centers on the distinction between supervision and control, and the autonomy of the Liga ng mga Barangay. The Liga, while under the general supervision of the DILG, is a constitutionally recognized organization of barangays with its own internal rules. The Liga’s own Implementing Guidelines mandated that appeals from BES decisions be taken to the National Liga Board. By issuing Memorandum Circular No. 97-193, which provided for judicial review instead, the DILG Secretary effectively altered these internal procedures. This act transcended the power of supervisionwhich is limited to ensuring that local governments or their units act within the lawand unlawfully exercised the power of control, which involves directing or substituting judgment. The DILG does not possess control over the Liga. Consequently, the questioned provision in the DILG Circular was ultra vires and void. The RTC therefore had no valid basis to assume jurisdiction. Quejano’s proper and exclusive remedy was an appeal to the National Liga Board, and his failure to exhaust this administrative remedy warranted the dismissal of his court petition.