G.R. No. L-76532 January 26, 1987
DR. FLOR J. LACANILAO, petitioner, vs. CAPT. JUAN DE LEON (P.N.), respondent.

FACTS

The Southeast Asian Fisheries Development Center (SEAFDEC) is an international organization established by treaty. Its Aquaculture Department, located in Iloilo, Philippines, is headed by a Department-Chief appointed by the SEAFDEC Council upon the recommendation of the Philippine government. In April 1986, following the EDSA Revolution, Minister of Agriculture and Food Ramon Mitra, by authority of the President, nominated Dr. Flor J. Lacanilao for the position. The SEAFDEC Secretary-General, via telex, acknowledged the nomination, requested Lacanilao to serve as Officer-in-Charge, and subsequently informed him that the Council, through a canvass of votes, had approved his appointment effective April 8, 1986, for a two-year term. Lacanilao assumed office and discharged its functions.
In November 1986, while Lacanilao was abroad at a SEAFDEC Council meeting, retired Navy Captain Juan de Leon, accompanied by retainers, forcibly took physical possession of the Aquaculture Department’s offices and stations. De Leon immediately began exercising the functions of Department-Chief, controlling finances, terminating consultants, and installing his own followers. De Leon claimed authority based on a subsequent nomination by the Minister of Natural Resources, acting for the President, and alleged that Lacanilao’s appointment was invalid due to procedural defects in the Council’s approval process.

ISSUE

Whether Juan de Leon has a legal right to occupy the position of Chief of the SEAFDEC Aquaculture Department and to exclude Flor J. Lacanilao therefrom.

RULING

The Supreme Court ruled in favor of petitioner Lacanilao and granted the writ of quo warranto. The legal logic rests on the proper interpretation of the SEAFDEC Agreement and the validity of the appointment process. The Court held that the power to appoint the Department-Chief is vested solely in the SEAFDEC Council. The Philippine government’s role is limited to nominating or recommending a candidate. Upon receipt of the Philippine government’s nomination of Lacanilao in April 1986, the SEAFDEC Council validly exercised its appointing power. The Council’s approval was effected through a canvass of votes by its members, a procedure expressly authorized by Article 7(5) of the SEAFDEC Agreement. Consequently, Lacanilao’s appointment was complete and lawful.
De Leon’s entry into office was founded on a separate, later nomination by a different ministry. Crucially, the SEAFDEC Council had not approved this subsequent nomination. De Leon’s physical takeover, therefore, constituted a mere usurpation without any color of legal title. The Court emphasized that the dispute concerns a position within an international organization, and the determinative act is the Council’s appointment, not the internal acts of the Philippine government. Since Lacanilao was the lawful appointee, De Leon had no right to occupy the office or exercise its functions. The Court ordered De Leon to cease and desist from performing the duties of the office and to vacate the premises.