G.R. No. L-24190 January 8, 1968
RAFAEL FALCOTELO, FERNANDO JOSE, REYNALDO ROXAS, SANTOS COMENDADOR and ULPIANO TAOPO, petitioners-appellants, vs. RESTITUTO GALI, CIPRIANO ILAGAN, SEGUNDO GONZALEZ, SALVADOR DE GUZMAN, ALEJANDRO PANGYARIHAN, ALFREDO MORENO and PAULINO PASCUAL, respondents-appellees.

FACTS

Petitioners, led by Rafael Falcotelo, were candidates proclaimed elected as barrio captain and councilmen of Bagong Barrio, Caloocan City, in an election held on January 12, 1964. They assumed their duties shortly thereafter. Respondents, led by Restituto Gali, were proclaimed elected to the same positions in a separate election held on January 26, 1964. Petitioners did not participate in this second election and opposed it through representations with the Commission on Elections and the PC Command. Petitioners filed a petition characterized as quo warranto on March 17, 1964, alleging respondents were unlawfully holding office. Respondents countered that the January 12 election was unauthorized, having been postponed by the old Barrio Council to January 26 due to lack of funds and boundary uncertainties, making the January 26 election the valid one. The City Court of Caloocan dismissed the case, holding it had jurisdiction but that the action was barred by the statute of limitations (Sections 173 and 174 of the Revised Election Code). Petitioners appealed to the Court of First Instance of Rizal, which dismissed the appeal on the ground that the City Court lacked original jurisdiction over quo warranto proceedings, which belong to the Supreme Court and Courts of First Instance.

ISSUE

The primary issue is whether the petition, whether treated as an election contest or a quo warranto proceeding, was filed within the prescriptive period allowed by law.

RULING

The Supreme Court dismissed the petition. It held that regardless of whether the action is characterized as an election contest or a quo warranto proceeding, it was filed out of time. For quo warranto based on ineligibility, the action must be filed within one week after proclamation. For an election contest on other grounds, it must be filed within two weeks after proclamation. Respondents were proclaimed on January 26, 1964, but the petition was filed on March 17, 1964, over seven weeks later, thus barred by the statute of limitations. The Court clarified that the provisions of the Revised Election Code (Republic Act No. 180) on these prescriptive periods govern the election of barrio officials, as the public interest demands the same prompt resolution of disputes. The Court modified its prior ruling in Bautista vs. De la Cruz to the extent of any conflict, holding that while the Barrio Charter (Republic Act No. 3590) governs jurisdiction (vesting it in the city or municipal court), the Revised Election Code governs the procedural periods for filing.