Limbona vs Mangelin

Facts:
Limbona was elected Speaker of the Regional Assembly of Central Mindanao. On October 21,
1987, Congressman Matalam invited Limbona in a consultation/dialogue with local government
officials. Limbona accepted the invitation and informed the Assembly Members through the
Assembly Secretary that there shall be no session in November as his presence was needed in the
House Committee hearing of Congress.
However, the Assembly held a meeting on November 2, 1987, and unseated Limbona from his
position. Limbona prays for the session to be declared null and void and that he still be declared
Speaker of the Regional Assembly.
Pending the case, the SC also received a resolution from the Assembly expelling Limbonas
membership.

Issues:
What is the extent of self-government given to the autonomous regions of Region XII?
Held:
Yes.
Autonomy is either decentralization of administration or decentralization of power.
Decentralization of Administration is the delegation by the central government of
administrative powers to political subdivisions in order to broaden the base of government
power and, in the process, to make local governments more responsive and accountable and
ensure their development as self-reliant communities and make them more effective partners in
the pursuit of national development and progress.
It also relieves the central government of the burden of managing local affairs and enables it to
concentrate on national concerns. An autonomous government under this category is under the
supervision of the national government through the President. The President exercises
supervision but has no control over them and does so only to ensure local affairs are
administered according to law.
Decentralization of Power, on the other hand, involves the abdication of power in favor of
autonomous local governments. The autonomous government is free to manage its affairs with
minimum intervention from central authorities. An autonomous government enjoying

autonomy under this category is only subject to the organic act creating it and accepted
principles on the effects & limits of autonomy.
PD 1618 mandates that the President shall have the power of general supervision and control
over autonomous regions. Hence, courts of law can assume jurisdiction. The courts can validly
review the removal of Limbona as Speaker.
Where a law is capable of 2 interpretations, one in favor of centralized power in Malacaang
and the other beneficial to local autonomy, the scales must be weighed in favor of autonomy.
Under Sec. 31 of Region XII Sanggunian Rules, sessions shall not be suspended or adjourned
except by direction of the Sangguniang Pampook.
However, the November 2 and 5, 1987 sessions are declared invalid since at the time Limbona
called the recess, it was not a settled matter whether or not he could do so. Secondly, the
invitation by the House of Representatives Committee on Muslim Affairs provides a plausible
reason for the intermission sought. Also, assuming that a valid recess could not be called, it does
not appear that respondents called his attention to his mistake. What appears is they opened the
sessions themselves behind his back in an apparent act of mutiny. Under these circumstances,
equity is on his side. The recess was called on the ground of good faith.