Case Digest (G.R. No. 128056-57) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1996, Senator Heherson T. Alvarez, Senator Jose D. Lina, Jr., Nicasio B. Bautista, Jesus P. Gonzaga, Solomon D. Maylem, Leonora C. Medina, Casiano S. Alipon and other private individuals (collectively, petitioners) sought prohibition and injunctive relief to stop implementation of Republic Act No. 7720 (“An Act Converting the Municipality of Santiago, Isabela into an Independent Component City to be known as the City of Santiago”). They named as respondents Executive Secretary Hon. Teofisto T. Guingona, Jr.; Secretaries Rafael Alunan (Local Government) and Salvador Enriquez (Budget); the Commission on Audit; and municipal officials of Santiago, including Mayor Jose Miranda, members of the Sangguniang Bayan, the Municipal Treasurer, and the Municipal Administrator. Petitioners contended that RA 7720 was void for two reasons: (1) it did not originate exclusively in the House of Representatives as required by Section 24, Article VI of the 1987 Constitution; and (2) the Municipal Case Digest (G.R. No. 128056-57) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Petitioners: Senator Heherson T. Alvarez, Senator Jose D. Lina, Jr., Nicasio B. Bautista, Jesus P. Gonzaga, Solomon D. Maylem, Leonora C. Medina, Casiano S. Alipon, et al.
- Respondents: Executive Secretary Teofisto T. Guingona, Jr., Secretary Rafael Alunan, Secretary Salvador Enriquez, Commission on Audit, Municipal Officials of Santiago, Isabela.
- Act in Question: Republic Act No. 7720 converting Santiago, Isabela into an independent component city.
- Petitioners’ Contentions
- Origination Defect: RA 7720 allegedly did not originate exclusively in the House of Representatives, in violation of Section 24, Article VI, 1987 Constitution.
- Income Deficiency: Municipality’s average annual income allegedly fell below the ₱20 million requirement under Section 450, Local Government Code, when IRAs were excluded.
- Legislative Chronology
- House Process
- HB No. 8817 filed April 18, 1993; public hearings May–December 1993; approved 2nd Reading December 13, 1993; 3rd Reading December 17, 1993; transmitted to Senate January 28, 1994.
- Senate Process
- SB No. 1243 filed May 19, 1993; hearings February 23, 1994; Committee Report No. 378 adopted March 3, 1994; approved 3rd Reading March 14, 1994.
- Enrollment and Plebiscite
- House concurrence on Senate amendments March 22, 1994; enrolled bill signed May 5, 1994; plebiscite held July 13, 1994 approving conversion.
- Petition for Prohibition filed January 31, 1996; Resolution of En Banc February 10, 1997.
Issues:
- Whether Internal Revenue Allotments (IRAs) must be included in the computation of a municipality’s average annual income for city conversion under Section 450, Local Government Code.
- Whether RA 7720 originated exclusively in the House of Representatives as required by Section 24, Article VI, 1987 Constitution, despite the Senate’s passage of SB No. 1243.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)