MUNICIPALITY OF SAN NARCISO QUEZON V.

MENDEZ
FACTS: The municipal district of San Andres was created pursuant to an executive order. After
30 years, the municipality of San Narciso, its other province, sought the declaration of that
executive order contending that since it is a presidential act, it was a usurpation of the inherent
powers of the legislature.
The municipality of San Andres filed a motion to dismiss alleging that the case had already
become moot and academic with the enactment of the Local Government Code which provides
that municipalities existing as of the date of the effectivity of this Code shall continue to exist
and operate as such.
ISSUE: WON the alleged unconstitutionality of the creation of the municipality of San Andres
has been cured by the enactment of the Local Government Code.
HELD: Petitioner challenged the legality of the creation of San Andres only after almost 30
years after its creation where in the meantime it existed as a duly created local government unit.
The Local Government Code provides that municipalities existing as of the date of the effectivity
of this Code shall continue to exist and operate as such.
Curative laws, which in essence are retrospective, and aimed at giving "validity to acts done that
would have been invalid under existing laws, as if existing laws have been complied with," are
validly accepted in this jurisdiction, subject to the usual qualification against impairment of
vested rights.