EO-created municipality DE FACTO if impliedly recognized, its acts accorded legal validity

We have since held that where a municipality created as such by executive order is later impliedly recognized and its acts are accorded legal validity, its creation can no longer be questioned. In Municipality of San Narciso, Quezon v. Mendez, Sr., this Court considered the following factors as having validated the creation of a municipal corporation, which like the Municipality of Sinacaban, was created by executive order of the President before the ruling in Palaez v. Auditor General: (1) the fact that for nearly 30 years the validity of the creation of the municipality had never been challenged; (2) the fact that following the ruling in Palaez no quo warranto suit was filed to question the validity of the executive order creating such municipality; and (3) the fact that the municipality, organized as part of municipal circuit court and considered part of a legislative district in the Constitution apportioning the seats in the House of Representatives. Above all, it was held that whatever doubt there might be as to the de jure character of the municipality must be deemed to have been put to rest by the local Government Code of 1991 (R.A. No. 7160), 442(d) of which provides that "municipal districts organized pursuant to presidential issuances or executive orders and which have their respective set of elective officials holding office at the time of the effectivity of this Code shall henceforth be considered as regular municipalities. [G.R. No. 105746. December 2, 1996]