LGC cures defect in creation of de facto municipalities

Moreover, following the ruling in Municipality of San Narciso, Quezon v. Mendez, Jr., 442(d) of the Local Government Code of 1991 must be deemed to have cured any defect in the creation of Sinacaban. This provision states: Municipalities existing as of the date of the effectivity of this Code shall continue to exist and operate as such. Existing municipal district organized pursuant to presidential issuances or executive orders and which have their respective set of elective municipal officials holding office at the time of the effectivity of the Code shall henceforth be considered as regular municipalities. [G.R. No. 105746. December 2, 1996]