Valle Verde vs Africa (Philippines Supreme Court Decision - 2009): Holdover Directors Cannot Appoint New Directors
Directors under law only have terms for one (1) year. If there is no election due to lack of quorum, sitting Directors have their terms end but their tenure on the Board continues. But, they cannot appoint new Directors if there are vacancies. Only the members may fill the seats through elections.
LEONARDO A. QUISUMBING
CONCHITA CARPIO MORALES