### Facts:
The root of this case springs from Baguio City’s legislative and executive branches’ efforts at local government reorganization. Enacted by the Sangguniang Panglungsod on January 1, 2004, Ordinance No. 01, Series of 2004, appropriated funds for restructuring several departments, including creating a Building and Architecture Office. Subsequently, Baguio City Mayor Braulio Yaranon issued Administrative Order No. 171 (AO 171), designating Engineer Oscar Flores as the Acting Building Official—a move that challenged the former structure where the City Engineer also acted as the Building Official, a position then held by Petitioner Leo Bernardez, Jr.
Bernardez filed a complaint, arguing that AO 171 and the resultant office restructuring usurped his duties as City Engineer and contravened the Local Government Code (LGC), which, in his view, mandated his role to include functions as the Building Official. Throughout the legal proceedings across the Regional Trial Court (RTC) and the Court of Appeals (CA), respondents maintained the legitimacy of AO 171’s issuance and its alignment with the Local Government Code and the National Building Code of the Philippines (NBC), highlighting broader government powers to reorganize and designate officials for efficient governance.
### Issues:
1. Whether AO 171 violates statutory provisions by appointing a separate Building Official, conflicting with the Local Government Code’s stipulation on the City Engineer’s dual role.
2. The validity of AO 171 amid claims it improperly stemmed from an appropriations measure.
3. Jurisdictional authority and propriety behind the DPWH Secretary’s power to designate Building Officials.
### Court’s Decision:
The Supreme Court dismissed the petition, affirming the CA’s decision supporting AO 171’s validity. The Court reasoned that subsequent events, such as Flores’ full appointment beyond the acting capacity, rendered concerns moot. Furthermore, it emphasized that local governments hold the discretion, under the LGC and the NBC, to organize departments and appoint officials for effective operation and governance. The Court also reaffirmed the Department of Public Works and Highways (DPWH) Secretary’s authority to appoint Building Officials, consistent with its prior rulings.
### Doctrine:
The case reiterates the principle that local government units have autonomous statutory authority to organize their internal structures and appoint officials for efficient administration. Consequently, the enactment of ordinances for departmental restructuring and designation of separate officials for roles traditionally combined, like the City Engineer and Building Official, is within the purview of local government discretion under the Local Government Code and the National Building Code, including their respective Implementing Rules and Regulations.
### Class Notes:
– **Local Government Autonomy**: Local governments have the authority to reorganize their departments to efficiently meet public service demands, under the guidelines of the LGC and relevant national codes.
– **Role of City Engineer vs. Building Official**: While historically combined, the LGC and the NBC allow for the differentiation of roles between a City Engineer and a Building Official, reflecting a shift towards specialized governance functions.
– **Mootness Principle**: Legal disputes can be deemed moot if subsequent events resolve the contention or if the original issue becomes irrelevant, emphasizing the courts’ preference for addressing live controversies with practical implications.
– **Administrative Authority of DPWH Secretary**: The Secretary of DPWH retains national-level authority to appoint or designate Building Officials, highlighting the centralized oversight intended by the NBC.
### Historical Background:
This case illustrates the evolving governance structures within local government units in the Philippines, reflecting statutory flexibilities intended by the Local Government Code and the National Building Code to adapt to complex administrative needs and enhance local autonomy. Through the legal contestation of AO 171, the judiciary reviewed the statutory framework governing local departmental organization and official designation, reinforcing legal precedents on governmental reorganization and administrative authority.
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