The President of the Philippines, through the Secretary of Local Government, possesses the authority to investigate and impose preventive suspensions on elective local officials in accordance with the procedures and limitations set forth in the Local Government Code (Batas Blg. 337), as this power is a component of the President's general supervision over local governments and was not abrogated by the 1987 Constitution; however, such power must not be exercised oppressively, and successive suspensions for numerous charges arising from acts committed prior to the first suspension may be curtailed to prevent what amounts to a de facto removal from office.

The cases arose from a series of administrative complaints filed in 1988 against Mayor Rodolfo Ganzon of Iloilo City and Sangguniang Panglunsod member Mary Ann Rivera Artieda. The complaints, lodged by various city officials, alleged offenses such as abuse of authority, oppression, grave misconduct, and culpable violation of the Constitution. These complaints led to investigations by the Department of Local Government and the imposition of preventive suspensions by the Secretary of Local Government, prompting the petitioners to question the Secretary's authority under the new constitutional framework emphasizing local autonomy.

• Ten administrative complaints were filed in 1988 against Mayor Rodolfo Ganzon of Iloilo City by various city officials for charges including abuse of authority, oppression, grave misconduct, disgraceful and immoral conduct, intimidation, culpable violation of the Constitution, and arbitrary detention.
• Complainant Mrs. Cabaluna, a clerk, alleged harassment through reassignment to a non-career service position due to political reasons.
• Complainant Dra. Felicidad Ortigoza, Assistant City Health Officer, claimed she was assigned tasks not befitting her position, her office was padlocked, and her salary withheld.
• Complainants Vice-Mayor Mansueto Malabor and Sangguniang Panglunsod members alleged that Councilor Larry Ong's office key was taken, and when they held office at Plaza Libertad in sympathy, Mayor Ganzon and armed security forcibly drove them away, later using a firetruck to douse people gathering at Freedom Grandstand.
• Complainant Pancho Erbite, a barangay tanod, alleged he was arrested and detained without warrant upon Mayor Ganzon's orders and was mauled by other detainees.
• The Department of Local Government (DLG) initiated hearings; petitioner Ganzon requested postponements and change of venue, some of which were denied.
• On August 11, 1988, the Secretary of Local Government issued a 60-day preventive suspension order against Mayor Ganzon based on finding probable grounds in some cases.
• On October 11, 1988, a second 60-day preventive suspension was ordered against Mayor Ganzon related to the Erbite case, but this was not enforced due to an RTC injunction.
• On May 3, 1990, the Secretary of Local Government issued a third 60-day preventive suspension order against Mayor Ganzon.
• Petitioner Mary Ann Rivera Artieda, a member of the Sangguniang Panglunsod of Iloilo City, was also charged and suspended by the respondent Secretary.
• Mayor Ganzon claimed denial of due process, alleging bias from the Secretary due to political rivalry, refusal to join the administration party, and refusal to operate a lottery; he also cited health reasons and hospitalization of a vital witness for postponement requests.

• The 1987 Constitution, by granting only "general supervision" to the President over local governments and deleting the phrase "as may be provided by law" (found in the 1935 Constitution), divested the President of the power to suspend and/or remove local officials.
• The constitutional intent is to strengthen local autonomy and strip the President of control over local governments, which includes disciplinary powers.
• The Secretary of Local Government, as the President's alter ego, lacks authority to suspend and remove local officials.
• Mayor Ganzon was denied due process of law in the administrative proceedings due to the alleged bias, prejudice, and hostility of the respondent Secretary, stemming from political differences and Ganzon's refusal to accede to certain requests.
• The respondent Secretary improperly denied Mayor Ganzon's requests for postponement and change of venue, which were based on valid and justifiable grounds.
• The hearing of complaints should have been deferred due to the ninety-day ban prescribed by Section 62 of Batas Blg. 337 prior to an election.
• The successive preventive suspensions imposed on Mayor Ganzon are oppressive, effectively amounting to removal from office without due process, and exceed the 60-day limit per offense.

• The Secretary of Local Government acted in accordance with the specific legal provisions of Batas Blg. 337 (the Local Government Code), particularly Sections 62 and 63, in conducting investigations and imposing preventive suspensions.
• The President's power of general supervision under the 1987 Constitution, even without the phrase "as may be provided by law," still allows the legislature to define the manner of its exercise, including the delegation of disciplinary powers over local officials.
• The deletion of "as may be provided by law" was intended to underscore local governments' autonomy from congressional control over their affairs, not to remove all legislative authority or the President's power to discipline local officials as provided by existing law.
• Local autonomy under the Constitution is not absolute and does not preclude accountability to the central government or the exercise of disciplinary powers by the President through the appropriate department secretary.
• The power of supervision inherently includes the power to investigate to ensure that subordinate officers perform their duties, and this is not incompatible with disciplinary authority provided by statute.
• Mayor Ganzon was not denied due process, as postponements are a matter of discretion for the hearing officer, and no grave abuse of discretion was shown in denying his requests.

• Whether the Secretary of Local Government, as the President's alter ego, has the authority to suspend and/or remove local officials under the 1987 Constitution.
• Whether the 1987 Constitution, by deleting the phrase "as may be provided by law" from the provision on presidential supervision over local governments, repealed Sections 62 and 63 of the Local Government Code (Batas Blg. 337) which grant such disciplinary powers.
• Whether Mayor Ganzon was denied due process of law in the administrative proceedings conducted by the Department of Local Government.
• Whether the successive preventive suspensions imposed on Mayor Ganzon are valid and permissible under the law.

• The petitions were DISMISSED. The Temporary Restraining Order previously issued was LIFTED. The suspensions of the petitioners were AFFIRMED, with a proviso for Mayor Ganzon.
• The President, acting through the Secretary of Local Government, retains the power to suspend and/or remove local officials as conferred by existing legislation (Batas Blg. 337). The 1987 Constitution did not divest the legislature of its right to provide administrative sanctions against local officials.
• The omission of the phrase "as may be provided by law" in the 1987 Constitution's provision on presidential supervision over local governments (Article X, Section 4) was intended to underscore local governments' autonomy from Congress and break Congress's "control" over local government affairs, but not to deprive the legislature of all authority over municipal corporations, particularly concerning discipline, nor to repeal existing laws like Batas Blg. 337.
• "Supervision" is not incompatible with disciplinary authority. While "control" means the power to alter or nullify acts of a subordinate, "supervision" means overseeing that subordinate officers perform their duties. Investigation is not inconsistent with overseeing.
• The Court found no clear evidence that Mayor Ganzon was denied due process. His claims of political motivation and bias were deemed speculative, and postponements are a matter of discretion for the hearing officer, with no grave abuse of discretion found.
• While affirming the third suspension, the Court ruled that Mayor Rodolfo Ganzon may not be made to serve future suspensions on account of any of the remaining administrative charges pending against him for acts committed prior to August 11, 1988, to prevent oppression from successive suspensions that could effectively remove him from office. The Secretary of Interior was ordered to consolidate all pending administrative cases against Mayor Ganzon. Delays in investigation due to his fault, neglect, or request shall not be counted in computing the time of suspension.
• The sixty-day suspension against petitioner Mary Ann Rivera Artieda was affirmed.

• Local Autonomy — Refers to a more responsive and accountable local government structure instituted through a system of decentralization. The Court clarified that under the 1987 Constitution, local autonomy involves a mere decentralization of administration, not of power (which would imply federalism). Local officials remain accountable to the central government in the manner the law may provide, and local governments are subject to regulation by the national legislature, consistent with the fundamental premise of autonomy.
• Presidential Power of General Supervision over Local Governments (Art. X, Sec. 4, 1987 Constitution) — The President shall exercise general supervision over local governments. This means overseeing or the power/authority of an officer to see that subordinate officers perform their duties. It does not mean control (the power to alter or modify or nullify or set aside what a subordinate officer had done). The Court held that this power of supervision is not incompatible with the power to investigate and discipline local officials when authorized by law (e.g., Batas Blg. 337), as investigation is a means to ensure laws are faithfully executed.
• Decentralization of Administration vs. Decentralization of Power — Decentralization of administration occurs when the central government delegates administrative powers to political subdivisions to broaden the base of government power, making local governments more responsive and accountable. The President exercises general supervision. Decentralization of power involves an abdication of political power in favor of autonomous local government units, which become accountable to their constituency, not central authorities. The Court held that the Constitution provides for decentralization of administration.
• Preventive Suspension (Sec. 63, Batas Blg. 337) — A measure that may be imposed on a respondent local official after issues are joined, if there is reasonable ground to believe the respondent committed the act(s) complained of, evidence of culpability is strong, the gravity of the offense warrants it, or continuance in office could influence witnesses or pose a threat to records. It shall not extend beyond sixty days. The Court reiterated its purpose is to prevent the accused from hampering the investigation, not as a penalty. Successive suspensions that effectively remove an official from office for the duration of their term are deemed oppressive and a denial of due process.
• Due Process in Administrative Proceedings — Requires notice and an opportunity to be heard. The Court found that Mayor Ganzon was given opportunities to answer charges and present evidence, and that denial of postponements, being discretionary, did not automatically amount to denial of due process absent grave abuse of discretion.
• Statutory Construction (Repeal by Implication) — The Court reiterated that repeals by implication are not favored. The change in constitutional language regarding presidential supervision did not, by itself, repeal the existing provisions of the Local Government Code (Batas Blg. 337) authorizing the President (through the DLG Secretary) to discipline local officials. Batas Blg. 337 remains in force.

• "Local autonomy, under the Constitution, involves a mere decentralization of administration, not of power, in which local officials remain accountable to the central government in the manner the law may provide;"
• "The change in constitutional language (with respect to the supervision clause) was meant but to deny legislative control over local governments; it did not exempt the latter from legislative regulation provided regulation is consistent with the fundamental premise of autonomy;"
• "'Supervision' and 'investigation' are not inconsistent terms: 'investigation' does not signify 'control' (which the President does not have);"
• "The plain truth is that this Court has been ill at ease with suspensions... The sole objective of a suspension... is simply 'to prevent the accused from hampering the normal cause of the investigation with his influence and authority over possible witnesses' or to keep him off 'the records and other evidence.' It is a means, and no more..."
• "Suspension finally is temporary, and as the Local Government Code provides, it may be imposed for no more than sixty days. As we held, a longer suspension is unjust and unreasonable, and we might add, nothing less than tyranny."

• Mondano vs. Silvosa, 97 Phil. 143 — Referenced for its discussion on the scope and extent of the President's power of supervision over local government officials versus the power of control, defining "supervision" as overseeing and "control" as the power to alter or nullify. The Court in Ganzon clarified that Mondano did not infer that supervision excludes the power of investigation.
• Lacson v. Roque, 92 Phil. 456 — Cited for the principle that the President enjoyed only supervision "as may be provided by law" and that removal/suspension is controlled by applicable law. Ganzon distinguished it by noting that in Lacson, the denial of presidential power was because no law allowed it, not because supervision itself precluded it.
• Hebron v. Reyes, 104 Phil. 175 — Similar to Lacson, cited for reiterating the rule on presidential supervision "as may be provided by law" and that suspension procedures must be strictly adhered to.
• Pelaez v. Auditor General, L-23825, December 24, 1965, 15 SCRA 569 — Stated that the President could not suspend an elective official except on appeal from the provincial board. Ganzon implies this was due to the specific legal framework then, not an inherent limitation of supervision.
• Ganzon v. Kayanan, 104 Phil. 484 — Cited as an instance where the Court sustained the President's power to discipline when the law gave him such power. Justice Mendoza's concurrence in this older case was noted.
• Limbona v. Mangelin, G.R. No. 80391, February 28, 1989, 170 SCRA 786 — Referenced for its distinction between decentralization of administration and decentralization of power, which the Ganzon court adopted in explaining local autonomy.
• Layno, Sr. v. Sandiganbayan, No. 65848, May 24, 1985, 136 SCRA 536 — Cited for the principle that protracted preventive suspension can raise a due process question and result in injustice, as it deprives the electorate of the services of their chosen official and nullifies the official's right to office even before guilt is established.
• Bagabuyo v. Davide, G.R. No. 87233, September 21, 1989 — Cited for the holding that Batas Blg. 337 is still in force and effect despite the approval of the 1987 Constitution.

• 1987 Constitution, Article X, Section 4 — "The President of the Philippines shall exercise general supervision over local governments." This provision was central to the petitioners' argument that the President's power was diminished. The Court interpreted it as not precluding legislatively delegated disciplinary powers.
• 1987 Constitution, Article X, Section 3 — "The Congress shall enact a local government code which shall provide for a more responsive and accountable local government structure instituted through a system of decentralization... and provide for the qualifications, election, appointment and removal, term, salaries, powers and functions and duties of local officials..." Cited to show that Congress is empowered to legislate on the removal of local officials, which can be delegated to the President.
• 1935 Constitution, Article X, Section 10(1) — "The President shall have control of all the executive departments, bureaus, or offices, exercise general supervision over all local governments as may be provided by law..." Cited for comparison to highlight the deletion of "as may be provided by law" in the 1987 Constitution concerning supervision over local governments.
• Batas Pambansa Blg. 337 (Local Government Code), Section 62 — "Notice of Hearing." Details the procedure for administrative complaints, requiring a verified answer and commencement of investigation. It also includes a ban on investigations and preventive suspensions within ninety days before an election. Referenced as the statutory basis for the DLG's actions and the petitioner's claim regarding the election ban.
• Batas Pambansa Blg. 337 (Local Government Code), Section 63 — "Preventive Suspension." Authorizes the Minister (now Secretary) of Local Government to impose preventive suspension on provincial or city officials under specified conditions and limits such suspension to sixty days. This was the primary legal basis for the suspensions challenged by the petitioners and upheld by the Court.
• Revised Administrative Code, Section 64(c) — Postulated the President's power of investigation over local government officials when the good of public service so requires. Referenced in the discussion distinguishing supervision from control.
• Revised Administrative Code, Section 79(c) — Vested authority in Department Heads. Referenced in Mondano regarding additional powers of supervision.