Sanciangco v.

Rono
GR. No. 68709
July 19, 1985
Topic: Ascertaining Legislative Intent

Facts:
Napoleon Sanciangco was elected Barangay Captain of Barangay Sta. Cruz, Ozamiz City, in the
17 May 1982 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,
Sanciangco was appointed by the President of the Philippines as a member of the City’s Sangguniang
Panlungsod. On 27 March 1984, Sanciangco 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, Sanciangco 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.
Roño, who ruled that since Sanciangco is an appointive official, he is deemed to have resigned from his
appointive position upon the filing of his Certificate of Candidacy.
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.

Issue:
Whether Local Government Minister Roño gravely abused its discretion in ruling that Sanciangco is
deemed to have resigned upon filing his COC

Held:
No. Sanciangco holds a public appointive position. He was appointed by the President as a
member of the City’s Sangguniang Panlungsod by virtue of his having been elected President of the
Association of Barangay Councils. This was pursuant to Section 3, paragraph 1 of BP 51 (An Act Providing
for the elective or Appointive Positions in Various Local Governments and for Other Purposes), and
reiterated by Section 183 of the Local Government Code (BP 337). Since Sanciangco is unquestionably an
appointive member of the Sangguniang Panlungsod of Ozamiz City, 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.
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 statute’s
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.
There was no violation of the equal protection clause since Section 13 of BP 697 applies alike to all
persons subject to such legislation under like circumstances and conditions. Neither was the Sanciangco
removed from office without due process of law since it was of his own choice that he ran for a seat in the
Batasan Pambansa. The consequence that followed his unsuccessful attempt at the elections arose from
law. In the case at bar, Sanciangco continues to be President of the Association of Barangay Councils. He
will need a reappointment by the President to be a part of the Sangguniang Panglungsod of Ozamis City.