Sanciangco v.

Rono
Facts: Petitioner was elected Barangay Captain of Barangay Poblacion, General
Santos, in the 10 May 1996 Barangay elections. Later, he was elected President of
the Association of Barangay Councils (ABC) of Ozamiz City by the Board of Directors
of the said Association. As the President of the Association, petitioner was appointed
by the President of the Philippines as a member of the Citys Sangguniang
Panlungsod. On 27 March 1999, petitioner filed his Certificate of Candidacy for the
14 May 1984 Batasan Pambansa elections for Misamis Occidental under the banner
of the Mindanao Alliance. He was not successful in the said election. Invoking
Section 13(2), Article 5 of BP 697, petitioner informed Vice-Mayor Benjamin A.
Fuentes, Presiding Officer of the Sangguniang Panlungsod, that he was resuming his
duties as member of that body. The matter was elevated to the Minister of Local
Government Jose A. Roo, who ruled that since petitioner is an appointive official,
he is deemed to have resigned from his appointive position upon the filing of his
Certificate of Candidacy.
Issue: Whether the accused is considered resigned from the latters filing of a
certificate of candidacy for the Batasan.
Held: Although it may be that Section 13(2), Batas Pambansa 697, admits of more
than one construction, taking into consideration the nature of the positions of the
officials enumerated therein, namely, governors, mayors, members of the various
sanggunians or barangay officials, the legislative intent to distinguish between
elective positions in section 13(2), as contrasted to appointive positions in section
13(l) under the all-encompassing clause reading any person holding public
appointive office or position, is clear. It is a rule of statutory construction that
when the language of a particular section of a statute admits of more than one
construction, that construction which gives effect to the evident purpose and object
sought to be attained by the enactment of the statute as a whole, must be followed.
A statutes clauses and phrases should not be taken as detached and isolated
expressions, but the whole and every part thereof must be considered in fixing the
meaning of any of its parts. The legislative intent to cover public appointive officials
in subsection (1), and officials mentioned in subsection (2) which should be
construed to refer to local elective officials, can be gleaned from the proceedings of
the Batasan Pambansa. Since petitioner is unquestionably an appointive member of
the Sangguniang Panlungsod of Ozamiz City, as he was appointed by the President
as a member of the Citys Sangguniang Panlungsod by virtue of his having been
elected President of the Association of Barangay Councils, he is deemed to have
ipso facto ceased to be such member when he filed his certificate of candidacy for
the 14 May 1984 Batasan elections.
The Supreme Court dismissed the petition and denied the writs prayed for, holding
that there was no grave abuse of discretion on the part of the officials; without
costs.

Barangay Chairman Alex David raised the question of when the barangay
elections should be held and questions the COMELECs schedule of holding such
elections on the 2nd Monday of May 1997. The COMELECs basis is R.A. 7160 or the
Local Government Code which mandates barangay elections every 3 years.
Petitioner David contends that an earlier law, R.A. 6679, should be the one followed.
R.A. 6679 provides that barangay elections should be held every 5 years. He also
contends that there is a violation of Art. 10, Sec. 8 of the Constitution.
ISSUE:
1. What the term of office of barangay officials is.
2. W/N there was a violation of Art. 10, Sec. 8 of the Constitution.
HELD:
1. It is basic in cases of irreconcilable conflict between two laws that the later
legislative enactment prevails. Furthermore, the Supreme Court in Paras v.
COMELEC
had the opportunity to mention when the next barangay election should be when it
stated that the next regular election involving the barangay office is barely 7
months away, the same having been scheduled in May 1997.
2. No. Art. 10, Sec. 8 of the Constitution provides that, The term of office of
elective local officials, except barangay officials, which shall be determined by law,
shall be three years It is not to be construed as prohibiting a 3-year term of office
for barangay officials.