G.R. No. L-31241 September 12, 1975
JESUS GALANO, ET AL., petitioners, vs. NEMESIO ROXAS, personally and as Mayor of San Mateo, Rizal, respondent.

FACTS

Petitioners, the former Chief of Police and twenty-three members of the San Mateo Police Department, filed a petition for mandamus and quo warranto against Mayor Nemesio Roxas. They sought to compel him to comply with a Civil Service Commission indorsement ordering their reinstatement with back salaries. The controversy arose after the 1967 local elections when respondent mayor assumed office. Between January 2 and 6, 1968, petitioners submitted their resignations, which the mayor accepted. They subsequently received terminal leave pay. Petitioners later claimed these were “courtesy resignations” submitted under threat.
Petitioners complained to the Police Commission and Civil Service Commission. After investigation, the Police Commission recommended declaring the resignations null and void and reinstating petitioners. The Civil Service Commission adopted this recommendation and directed the mayor to comply. The mayor instead sought reconsideration and, upon denial, referred the matter to the President, refusing to execute the reinstatement order. Petitioners then elevated the case to the Supreme Court.

ISSUE

Whether the Supreme Court can grant the petition for quo warranto and mandamus seeking the reinstatement of petitioners to their former positions.

RULING

The Supreme Court dismissed the petition. The ruling was based on two fatal procedural defects. First, the petition suffered from non-joinder of indispensable parties. The individuals appointed to replace the petitioners, whose appointments were allegedly invalidated by the Civil Service Commission’s order, were not included as parties to the case. Their legal interests would be directly affected by a judgment ordering reinstatement, as it would necessarily declare their right to hold office void. The absence of these indispensable parties deprives the court of jurisdiction to proceed, as judicial power cannot be exercised without them.
Second, the action was filed beyond the one-year prescriptive period for quo warranto. Jurisprudence firmly establishes that such an action to try title to a public office must be filed within one year from the date of the alleged unlawful ouster. Petitioners were separated from service in early January 1968 and were aware of the claimed illegality by January 10, 1968, when they filed their administrative complaints. Their judicial action, filed thereafter, was therefore time-barred. The Court emphasized that the pursuit of administrative remedies does not interrupt this one-year period. Public interest demands the speedy resolution of disputes over public office. Consequently, petitioners’ remedy, if any, lay solely with the administrative authorities, and judicial relief was no longer available.