Facts:

The case involves two consolidated petitions: the first filed by Datu Firdausi I.Y. Abbas and several other petitioners representing taxpayers from Mindanao against the Commission on Elections (COMELEC) and Honorable Guillermo C. Carague, the Secretary of Budget and Management; and the second filed by Atty. Abdullah D. Mam-o against the same respondents. The petitions were submitted to the Supreme Court of the Philippines, which rendered its decision on November 10, 1989. The controversy arose from a plebiscite scheduled for November 19, 1989, concerning the establishment of an Autonomous Region in Muslim Mindanao, as mandated by Republic Act No. 6734. The petitioners sought to enjoin the COMELEC from conducting the plebiscite and to prevent the release of funds for this purpose, arguing that R.A. No. 6734 was unconstitutional. The petitioners contended that certain provisions of the Act violated the Constitution and conflicted with the Tripoli Agreement, which aimed to estab...

Facts:

Context and Legislative Background

• The controversy arises from the plebiscite scheduled for November 19, 1989, in thirteen provinces and nine cities in Mindanao and Palawan, as mandated by Republic Act No. 6734, also known as the Organic Act for the Autonomous Region in Muslim Mindanao (ARMM).
• The Organic Act was enacted pursuant to the constitutional provisions which, for the first time under the 1987 Constitution, recognized the creation of autonomous regions in the Philippines.
• The Act incorporates provisions from the historic Tripoli Agreement (effective December 23, 1976), which originally set forth the framework for autonomy in the southern Philippines, enumerating the areas for such autonomy.

Parties Involved

• Petitioners
• Represented by taxpaying leaders including Datu Firdausi I.Y. Abbas, Datu Blo Umpa, and others, representing the other taxpayers of Mindanao, as well as ATTY. Abdullah D. Mam-O, among others.
• Their petition seeks to enjoin the Commission on Elections (COMELEC) from conducting the plebiscite and to restrain the Secretary of Budget and Management from releasing funds assigned for the plebiscite.
• Respondents
• The Commission on Elections (COMELEC).
• The Honorable Guillermo C. Carague, Secretary of Budget and Management.

Statutory and Constitutional Framework

• Republic Act No. 6734
• Establishes the legal framework for the creation of the autonomous region, conditioned upon the results of a plebiscite.
• Contains provisions regarding the composition of the region, clarifying that only the provinces, cities, and geographic areas voting favorably in the plebiscite shall be included.
• Constitutional Provisions
• Article X of the 1987 Constitution provides for the establishment of autonomous regions and sets the conditions for their creation.
• Specific sections (Sec. 15 to Sec. 21) define the powers, functions, and limitations, including the supervisory role of the President and the requirement for an organic act approved by a plebiscite.
• The Transitory Provisions (Article XIX) elaborate on the operational details such as the timing and conditions for the plebiscite and the organization of the regional government.

Underlying Disputes and Arguments Raised

• The petitioners challenge the constitutional validity of R.A. No. 6734 based on several grounds, which they broadly categorize as:
• Alleged violation of the Commission’s role by unconditionally creating an autonomous region.
• The contention that certain provisions of the Organic Act conflict with the Tripoli Agreement.
• Specific Concerns Raised by Petitioners
• Constitutional Issue on Autonomous Region’s Creation
• Argument that the provision declaring the creation of the autonomous region is absolute, regardless of the plebiscite outcome, which contradicts the constitutional requirement of acquisition through majority votes in each constituent unit.
• Conflict with the Tripoli Agreement
• Petitioners assume that, as a binding international agreement, the Tripoli Agreement should override or limit the scope of the Organic Act.

ii. They argue that the Act improperly expands the scope of the autonomous region.

Issue:

Constitutional Validity of the Organic Act (R.A. No. 6734)

• Does the Act unconditionally create an autonomous region in Muslim Mindanao, thereby subverting the requirement that such creation depends on a plebiscite outcome?
• Is the Act’s provision that the region is constituted solely by areas voting favorably consistent with the constitutional framework?

Conflict with the Tripoli Agreement

• Does R.A. No. 6734 conflict with the provisions of the Tripoli Agreement, and if so, does the Agreement have a binding effect on the Philippine Government?
• If the Tripoli Agreement were binding, would it alter or supplement the legislative provisions contained in the Organic Act?

Equal Protection and Classification

• Does the inclusion of certain areas which may not share common historical and cultural characteristics violate the equal protection clause of the Constitution?
• Is Congress’s classification and delineation of areas for autonomy a permissible exercise of legislative discretion?

Free Exercise of Religion

• Is the mandate to apply national law over conflicts between the Muslim Code (Shariʼah) and national law a violation of the constitutional guarantee on free exercise of religion?

Presidential Power and Oversight Committee Provisions

• Is conferring the power on the President to merge administrative regions in conflict with the constitutional processes for merging local government units?
• Are the provisions providing for an Oversight Committee that supervises the transfer of powers and properties to the regional government valid, or do they in effect delay the creation of the autonomous region contrary to constitutional mandates?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)