Lex Rex Ph

Limbona vs. Magelin Digest


Petitioner Sultan Alimbusar Limbona was chosen to be part of a local governing body, the Sangguniang Pampook, and became its Speaker of an autonomous region in Mindanao. He was then invited by a national representative to discuss matters affecting the local autonomy of Regions IX and XII. Limbona advised the local Assembly to pause meetings in November so he could attend these important discussions in the House Committee.  Some members went ahead with meetings anyway and said Limbona’s leadership role was now open. The court received a formal statement saying Limbona was “expelled” for reasons like unauthorized salary payments, which led to financial issues for some members, and for starting a legal case that should have been handled within the local body.


Are the so-called autonomous governments of Mindanao, as they are now constituted, subject to the jurisdiction of the national courts? Yes.

  • Yes, they are still “subject to the moderating hand of [the] Court” in the event of grave abuse of discretion (Judicial oversight still present);
  • Autonomy does not mean complete independence from the national government.

In other words, what is the extent of self-government given to the two autonomous governments of Region IX and XII?

  • Autonomy is more administrative in nature only. The decentralization is for administration only.
    • They only have Decentralization of Administration not Decentralization of Power or self-immolation

What is the Decentralization of Power?

A more complete transfer. A more complete transfer of power from the central government to autonomous local government units. 

Accountability to the constituency. Here, the local government is accountable not to the central authorities but to its constituency.

Not complete independence from the national government. They are not entirely autonomous in the sense of being completely independent of the national government.

Local Autonomy is limited to the confines of national laws and general supervision of the President. This autonomy allows the local governments to exercise a certain degree of self-governance but within the confines of national laws and the general supervision of the President.

The purpose of this autonomy is to make local governments more responsible and accountable to their constituents.

What are the Limits of the President’s Power in Decentralization of Administration?

  1. General supervision
  2. Cannot substitute his own judgments

The purpose of their creation:

Autonomous regions were created within the framework of national sovereignty and territorial integrity of the Republic of the Philippines and its Constitution. The decree details various matters over which the National Government retains jurisdiction and competence, such as national defense, foreign relations, and monetary policy among others. It also states that the President shall have the “power of general supervision and control over the Autonomous Regions.

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