G.R. No. 80391 February 28, 1989
SULTAN ALIMBUSAR P. LIMBONA, petitioner, vs. CONTE MANGELIN, et al., respondents.

FACTS

Petitioner Sultan Alimbusar Limbona was a member and the elected Speaker of the Sangguniang Pampook (Regional Legislative Assembly) of Region XII. In October 1987, Congressman Datu Guimid Matalam, Chairman of the House Committee on Muslim Affairs, invited petitioner and another regional speaker to assist in congressional consultations on autonomy from November 1 to 15, 1987. In response, petitioner instructed the Acting Secretary of the Assembly to inform all members that there would be no sessions in November, as their presence at the congressional hearings took precedence. Defying this instruction, a group of assemblymen, constituting a quorum, convened on November 2, 1987. During this session, they declared the Speaker’s seat vacant. They reaffirmed this action in a subsequent session on November 5, 1987. Later, the Sangguniang Pampook itself passed a resolution expelling petitioner from membership. Petitioner thus filed this action seeking to nullify the proceedings that declared his seat vacant and to secure his reinstatement as member and Speaker.

ISSUE

The primary issue is whether the Sangguniang Pampook of Region XII validly declared the position of Speaker vacant and subsequently expelled petitioner from membership, considering his declaration of a recess for the assembly to attend congressional committee hearings.

RULING

The Supreme Court GRANTED the petition, ordering the reinstatement of petitioner as member and Speaker. The Court ruled that the Sangguniang Pampook acted without jurisdiction in expelling the petitioner. The legal logic rests on the nature of the Sangguniang Pampook under the then-operative laws. Presidential Decree No. 1618, which created the autonomous regions, placed the Sangguniang Pampook under the administrative supervision of the President of the Philippines. Crucially, the Court distinguished “supervision” from “control.” Supervision means overseeing to ensure that rules are followed, but it does not include the power to alter or reverse the subordinate’s actions. Control, however, implies the power to substitute one’s own judgment. The Sanggunian, while autonomous, was not entirely independent from the national government’s supervisory authority. The Court found that the expulsion of a member is a grave power that affects the legislative branch’s integrity. Such a power could not be exercised unilaterally by the Sanggunian without being subject to review by the President, to whom it was administratively responsible. Since the expulsion was done without such review and in defiance of the President’s implicit interest (through the congressional invitation which the Speaker was following in good faith), the act was invalid. Furthermore, the Court upheld the petitioner’s good faith in declaring a recess to comply with a legitimate congressional request aimed at discussing the very autonomy of their region. The subsequent expulsion was therefore declared null and void for lack of jurisdiction and for being contrary to the administrative hierarchy established by law.