Facts:

The case at hand is titled Victorino B. Aldaba, Carlo Jolette S. Fajardo, Julio G. Morada, and Minerva Aldaba Morada v. Commission on Elections, and was decided by the Philippine Supreme Court en banc under G.R. No. 188078 on January 25, 2010. The petitioners are taxpayers, registered voters, and residents of Malolos City, who challenged the constitutionality of Republic Act No. 9591 (RA 9591). This law aimed to create a separate legislative district for Malolos City, Bulacan, claiming that the city met the necessary population requirement for such a designation. Prior to RA 9591’s enactment, Bulacan Province had four legislative districts, with Malolos City included in the First District alongside several municipalities. On May 1, 2009, RA 9591 lapsed into law, based on House Bill No. 3693 and Senate Bill No. 1986, which asserted that Malolos’ population would reach at least 250,000 by the year 2010. However, the population at the time of bill filing in 2007 was reportedly 223,

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Facts:

Background and Legislative Context

• Before May 2009, Bulacan was divided into four legislative districts, with the First Legislative District comprising Malolos City together with the municipalities of Hagonoy, Calumpit, Pulilan, Bulacan, and Paombong.
• On May 1, 2009, Republic Act No. 9591 was enacted, amending the City of Malolos’ Charter by creating a separate legislative district for the city.
• The law was premised on the claim that Malolos City would soon meet the constitutional requirement of having a population of at least 250,000 to warrant its own legislative district.

Population Data and Certification

• At the time legislative bills were filed in Congress (in 2007), the official 2007 Census had recorded Malolos City’s population at 223,069.
• An undated certification issued by Regional Director Alberto N. Miranda of the NSO indicated that:
• The population of Malolos City as of May 1, 2000 was 175,291 according to the 2000 census.
• Using a growth rate of 3.78% per annum (calculated from the 1995–2000 period), the projected population for the year 2010 was computed at 254,030.
• The certification was requested by Mayor Danilo A. Domingo in connection with the creation of the lone congressional district.

Petition and Legal Challenge

• Petitioners—composed of Victorino B. Aldaba, Carlo Jolette S. Fajardo, Julio G. Morada, and Minerva Aldaba Morada, all identified as taxpayers, registered voters, and residents of Malolos City—challenged the constitutionality of RA 9591.
• The primary contention was that Malolos City failed to meet the constitutional minimum population threshold of 250,000 as mandated by Section 5(3), Article VI of the 1987 Constitution and Section 3 of the Ordinance appended thereto.
• The petition questioned the validity of relying on demographic projections—notably an undated certification from an NSO Regional Director—for the creation of a legislative district.

The Role of the Certification and Executive Order No. 135

• The NSO Regional Director’s certification was based on demographic projections which, as applied, indicated that the population would be less than 250,000 by the election year when the proper growth rate was applied.
• The certification was found deficient because it was not issued by the NSO Administrator or a designated certifying officer as required by Executive Order No. 135.
• The certification did not comply with the guideline that intercensal population projections must be calculated as of the middle of each year, and it lacked the necessary declaration of official status by the National Statistical Coordination Board (NSCB).

Related Arguments and Dissenting Views

• The Office of the Solicitor General (OSG) argued that Congress’ use of population projections should not be justiciable because it involves legislative judgment on data and methodology for meeting constitutional requirements.
• Dissenting opinions stressed that a city is only entitled to a legislative district in the immediately following election after its actual or duly certified attainment of the 250,000 population threshold.
• There was also debate regarding whether a plebiscite was needed, with dissent emphasizing that the creation of a separate district was a legislative matter rather than one for local referendum.

Issue:

Qualification of the City for Its Own Legislative District

• Whether Malolos City truly met or was projected to meet the constitutional minimum population requirement of 250,000 prior to the 10 May 2010 elections.
• Whether the use of an unofficial, undated demographic projection, not issued by the proper NSO authority, could be accepted as a basis for reapportioning legislative districts.

Validity and Reliability of Population Projections

• Whether the demographic projection based on an assumed growth rate of 3.78% per annum was legally reliable and methodologically sound.
• Whether compliance with the procedural requirements under Executive Order No. 135 was strictly necessary for any certification used in the legislative apportionment process.

Scope of Judicial Intervention

• Whether the courts have the authority to review and invalidate a legislative reapportionment law when it allegedly fails to comply with the constitutional and ordinance mandate regarding population thresholds.
• Whether the argument that such legislative decisions are non-justiciable political questions holds merit in light of the checking function of the judiciary.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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