Viola vs. Alunan III (1997)Facts: Cesar G. Viola, filed petition for prohibition challenging the validity of Art.

III, 1-2 of the Revised Implementing Rules and Guidelines for the General Elections of the Liga ng mgaBarangay Officers in so far as they provide for the election of first, second and third vice presidents and for auditors for the National Liga ng mga Barangay and its chapters. The issue iswhether or not Section 1-2 of the Implementing Rules are valid? Held: The creation of the additional positions is authorized by 493 of LGC which in factrequires and not merely authorizes the board of directors to "create such other positions asit may deem necessary for the management of the chapter" and belies petitioner's claim that 493limits the officers of a chapter to the president, VP, 5 members of the board of directors,secretary, and treasurer. Also, the creation of these positions was actually made in theconstitu tion and by-laws of the Liga ng mga Barangay adopted by the 1st Barangay NationalAssembly. Congress can delegate the power to create positions such as these. Section493embo dies a fairly intelligible standard deemed necessary for the management of the chapters,".There is no undue delegation of power by Congress. SC decisions have upheld the validity of reorganization statutes authorizing the President of the Philippines to create, abolish or mergeoffices in the executive department