QUEZON CITY, METRO MANILA – JANUARY 6, 2025 – In a decisive ruling that reinforces the primacy of its new constitution and the will of its members, the Supreme Tribunal of the Fraternal Order of Eagles – Philippine Eagles, Inc. (TFOE-PE) has affirmed the election of Eagle Ronald F. De Los Santos as the organization’s National President for the 2025-2026 term, effectively quashing a previous, controversial decision that had sought to overturn the election results.
The resolution, dated January 6, 2025, resolves a tumultuous internal conflict that pitted the organization’s election body and its newly elected president against appellant Eagle Ricky S. Bulacan.
At the Heart of the Controversy: A “Void” Decision
The dispute stemmed from a purported decision issued on January 3, 2025, by a previous set of tribunal members. That decision had allegedly favored appellant Bulacan. However, the newly constituted Supreme Tribunal has declared that January 3 ruling “void ab initio” (invalid from the start), rendering it legally worthless.
The Tribunal based its nullification on three critical grounds:
- Lack of a Proper Tribunal: The 2024 TFOE-PE Constitution, which is “immediately enforceable,” requires the Supreme Tribunal to be composed of eleven (11) Chancellors. The January 3 decision was signed only by a defunct Supreme Chancellor and two other members, far short of the required quorum. The Tribunal stated that the body that issued the previous ruling was “no longer existent” under the new charter.
- An Ineligible Leader: The new constitution mandates that the Supreme Chancellor “must be a lawyer.” The previous Supreme Chancellor, Eagle Ricaredo Llorca, is a non-lawyer. The ruling emphasized that the word “must” imposes a mandatory legal obligation, thus barring Llorca from legitimately leading the tribunal or acting on vital matters.
- Violation of Due Process: The January 3 proceeding was conducted without notice and hearing, denying Eagle Ronald F. De Los Santos an opportunity to be heard. The Tribunal condemned this as a violation of constitutionally guaranteed procedural due process, stating, “a party who is to be affected… must be given his day in court.”
The Will of the People Prevails
The resolution firmly anchored its final decision on the legitimacy of the November 24, 2024, general election. The Tribunal noted that the election was conducted successfully with no standing disqualification order against De Los Santos at the time of his proclamation.
Citing the legal maxim “Salus Populi est Suprema Lex” (The welfare of the people is the supreme law), the Tribunal declared it has “no business to dwell in the purview of political questions and would rather submit to the choice of the people.”
Furthermore, the ruling invoked Philippine jurisprudence, specifically the case of Labo vs. Comelec, to assert that a losing candidate cannot be proclaimed as a substitute winner. It clarified that in such a scenario, a rule of succession should be followed, not a substitution by a defeated candidate.
The Final Ruling
After a thorough review, the Supreme Tribunal:
- AFFIRMED the November 23, 2024, decision of the Philippine Eagles Election Commission (Phielecom) En Banc, which had given due course to De Los Santos’ certificate of candidacy.
- REVERSED and declared NULL and VOID the January 3, 2025, decision of the previous tribunal.
- AFFIRMED the election and proclamation of Eagle Ronald F. De Los Santos as the National President of the Fraternal Order of Eagles for the 2025-2026 Eagle Year.
The resolution was signed by a fully constituted tribunal led by Supreme Chancellor Eagle Atty. Virgilio S. Ferrer II, along with six other Associate Chancellors, all of whom are legally qualified under the new constitution.
This ruling marks a significant moment for the fraternal organization, underscoring its commitment to the rule of law, due process, and the democratic will of its membership.#
