G.R. No. 255453 & G.R. No. 255543. November 24, 2021.
SANGGUNIANG PANLUNGSOD NG VALENZUELA CITY, ET AL. VS. SK CHAIRPERSON PEDERASYON PRESIDENT JANINE ALEXANDRA R. CARLOS; and SK CHAIRPERSON JANINE ALEXANDRA R. CARLOS VS. SANGGUNIANG PANLUNGSOD NG VALENZUELA CITY, ET AL.

FACTS

Janine Alexandra R. Carlos was the elected Sangguniang Kabataan (SK) Chairperson of Brgy. Marulas, Valenzuela City, and the elected president of the SK Federation of Valenzuela City, making her an ex-officio member of the Sangguniang Panlungsod. The SK Federation observed her remiss in duties due to unjustified absences, hindering projects. Consequently, on September 29, 2018, 31 of 33 SK Federation members approved a resolution installing Vice President Chiqui Marie N. Carreon as the new president. The Sangguniang Panlungsod recognized this change via Resolution No. 1169 on October 1, 2018. Carlos filed a petition for certiorari before the Regional Trial Court (RTC), arguing her removal was without due process and that the SK Federation had no power to remove her without following DILG-COMELEC-NYC Joint Memorandum Circular (JMC) No. 2017-01, which allegedly required complaints to be lodged with the Office of the President (OP).
Separately, on October 16, 2018, an administrative complaint was filed before the Sangguniang Panlungsod against Carlos for failure to formulate and submit the required Comprehensive Barangay Youth Development Plan and Annual Barangay Youth Investment Program under Republic Act (R.A.) No. 10742 (SK Reform Act of 2015). Carlos argued the Sangguniang Panlungsod lacked jurisdiction over her, asserting her removal should be governed by the Local Government Code (LGC).
On January 21, 2019, the Sangguniang Panlungsod found Carlos guilty and ordered her removal from office as SK Chairperson. The RTC dismissed her certiorari petition, ruling the proper remedy was an appeal to the OP under JMC No. 2017-01, which she failed to do within the 30-day period. Carlos appealed to the Court of Appeals (CA) in two cases: CA-G.R. SP No. 160131 (questioning her removal as SK Federation President) and CA-G.R. SP No. 162895 (questioning her removal as SK Chairperson).

ISSUE

The primary issues were: (1) Whether the Sangguniang Panlungsod had jurisdiction to recognize the removal of Carlos as SK Federation President and to order her removal as SK Chairperson; and (2) What law governs the disciplinary proceedings against an SK official—the Local Government Code or R.A. No. 10742 and its implementing rules.

RULING

The Supreme Court consolidated the petitions and ruled as follows:
1. Regarding Removal as SK Federation President (CA-G.R. SP No. 160131): The Court affirmed the CA’s decision declaring Sangguniang Panlungsod Resolution No. 1169 void for lack of jurisdiction. Citing Section 32 of JMC No. 2017-01, the Court held that the Office of the President has exclusive jurisdiction over complaints for disciplinary action, suspension, and removal against the president of an SK Federation in a highly urbanized city. Since Valenzuela City is a highly urbanized city, the Sangguniang Panlungsod acted without jurisdiction in recognizing Carlos’s removal as Federation President. Therefore, her remedy of certiorari was proper to assail the void resolution.
2. Regarding Removal as SK Chairperson (CA-G.R. SP No. 162895): The Court affirmed the CA’s decision upholding the validity of Carlos’s removal as SK Chairperson of Brgy. Marulas. The Court ruled that R.A. No. 10742 , being a special and more recent law, governs the discipline and removal of SK officials, not the Local Government Code. The Sangguniang Panlungsod complied with the procedures under R.A. No. 10742 and its rules. Carlos was afforded due process, and the ground for her removal—failure to formulate the required youth development plan and investment program within the prescribed period without justifiable reason—is a valid ground under Section 18(d) of R.A. No. 10742 . Her failure to participate in the proceedings did not negate the validity of the process.
The Court also noted that the CA’s Consolidated Resolution, which dismissed related motions as moot and academic, was in order. The petitions were resolved accordingly, with no pronouncement as to costs.