G.R. No. 84663 , 85012, 86393, 87601, 87602, 87792, 87935, 89072, 90205 | August 24, 1990
Johnny D. Supangan, Jr., et al., petitioners, vs. Hon. Luis T. Santos, Secretary of the Department of Local Government, et al., respondents.

FACTS

These consolidated petitions challenge the validity of appointments made by the Secretary of the Department of Local Government (DLG) to fill sectoral representative seats in various local legislative bodies (Sanggunians). The appointments involved representatives for sectors such as youth, agricultural labor, and industrial labor. In G.R. No. 84663 , petitioner Johnny Supangan, Jr., a duly elected Kabataang Barangay Provincial Federation President, was appointed as the youth representative to the Pangasinan Sangguniang Panlalawigan in 1985. In 1988, respondent DLG Secretary Luis Santos designated Marissa Domantay to replace him via a letter, despite Domantay not being an elected federation president. Similar controversies arose in other cases where the DLG Secretary appointed individuals to sectoral seats, often replacing incumbents whose terms were purportedly unexpired or appointing persons whose sectoral affiliations were questioned.
The common thread is the assertion by petitioners that the DLG Secretary lacked the legal authority to make such designations. They argued that the applicable laws, including the Local Government Code (Batas Pambansa Blg. 337), provided specific qualifications and modes for selecting these sectoral representatives, which did not include unilateral appointment by the DLG Secretary. The respondents, in turn, relied on the Secretary’s powers under administrative orders and his role as the President’s alter ego to justify the appointments as necessary to fill vacancies and ensure sectoral representation.

ISSUE

The central issue is whether the Secretary of the Department of Local Government possessed the legal authority to appoint or designate sectoral representatives to the various local Sanggunians.

RULING

The Supreme Court ruled that the DLG Secretary had no such authority, declaring the questioned appointments null and void. The legal logic rests on the principle of local autonomy and the specific statutory framework governing local legislative bodies. The Court examined the Local Government Code and related laws, which outlined the composition of the Sanggunians. For sectoral representatives, such as those from the youth or labor sectors, the law prescribed specific qualifications and modes of selection, typically involving election by their respective sectoral organizations or federations (e.g., election as Kabataang Barangay Federation President for the youth seat).
The Court held that the power to appoint or designate these representatives was not vested in the DLG Secretary by any provision of law. The Secretary’s general administrative supervision over local governments did not extend to the power to appoint members of local legislative bodies, as this would violate the principle of local autonomy and the elective nature of the positions. The seats were meant to be filled by the sectors themselves through their own processes, not by executive fiat. Consequently, appointments made by the Secretary, including those replacing incumbents without legal cause, were ultra vires acts without legal effect. The Court ordered the reinstatement of unlawfully removed incumbents and upheld only those appointments in specific cases (e.g., G.R. No. 85012 and 90205) where the appointees were found to have been selected in accordance with the legally prescribed manner, thus not relying on the Secretary’s invalid authority.