Limbona vs Conte Mangelin, 170 SCRA 786

ISSUE:  Is the expulsion valid? Are the so-called autonomous governments of Mindanao, as they are now constituted, subject to the jurisdiction of the national courts? In other words, what is the extent of self-government given to the two autonomous governments of 

FACTS:  Petitioner was appointed member of the Sanguniang Pampook, Regional Autonomous Government and was later elected Speaker of the Regional Legislative Assembly. Congressman Datu invited petitioner in his capacity as Speaker of the Assembly for consulations and dialogues on the recent and present political developments and other issues affecting Regions IX and XII hopefully resulting to chart the autonomous governments of the two regions as envisioned and may prod the President to constitute immediately the Regional Consultative Commission as mandated by the Commission. Consistent with the said invitation, Petitioner addressed all Assemblymen that there shall be no session in November as “our presence in the house committee hearing of Congress take (sic) precedence over any pending business in batasang pampook … .” In defiance of Petitioner’s advice, After declaring the presence of a quorum, the Speaker Pro-Tempore was authorized to preside in the session. On Motion to declare the seat of the Speaker vacant, all Assemblymen in attendance voted in the affirmative. 

RATIO DECIDENDI:  We therefore order reinstatement, with the caution that should the past acts of the petitioner indeed warrant his removal, the Assembly is enjoined, should it still be so minded, to commence proper proceedings therefor in line with the most elementary requirements of due process. And while it is within the discretion of the members of the Sanggunian to punish their erring colleagues, their acts are nonetheless subject to the moderating band of this Court in the event that such discretion is exercised with grave abuse. the Decree PD 168 established “internal autonomy” in the two regions “[w]ithin the framework of the national sovereignty and territorial integrity of the Republic of the Philippines and its Constitution,” with legislative and executive machinery to exercise the powers and responsibilities specified therein