Case Digest (G.R. No. 189793) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 189793, decided April 7, 2010, petitioners Senator Benigno Simeon C. Aquino III and Mayor Jesse Robredo, acting as public officers, taxpayers and citizens, assailed Republic Act No. 9716. Enacted as House Bill No. 4264, RA 9716 was signed by President Gloria Macapagal-Arroyo on October 12, 2009 and became effective on October 31, 2009. It reconfigured the First and Second Legislative Districts of Camarines Sur (2007 population 1,693,821) to create a new district. Prior to RA 9716, Camarines Sur had four districts with populations of 417,304; 474,899; 372,548; and 429,070 respectively. The law combined municipalities from the First and Second Districts to form a new Second District, reducing the proposed First District to 176,383 inhabitants—below the alleged 250,000 constitutional minimum. Petitioners sought via Rule 65 certiorari and prohibition to nullify RA 9716 and to enjoin the Commission on Elections from implementing it. Respondents argued lack of jurisdiction Case Digest (G.R. No. 189793) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Petitioners
- Senator Benigno Simeon C. Aquino III
- Mayor Jesse Robredo
- Respondent
- Enacted Law and Background
- Republic Act No. 9716 (RA 9716)
- Reapportionment Details
- Pre-RA 9716 (2007 Census total population: 1,693,821)
- 1st District: nine municipalities; population 417,304
- 2nd District: ten municipalities/city; population 474,899
- 3rd District: ten municipalities; population 372,548
- 4th District: six municipalities/city; population 429,070
- Post-RA 9716 (creation of 5th District)
- 1st District: five municipalities; population 176,383
- 2nd District: seven municipalities; population 276,777
- 3rd District: (formerly 2nd) seven municipalities/city; population 439,043
- 4th District: (formerly 3rd) ten municipalities; population 372,548
- 5th District: (formerly 4th) six municipalities/city; population 429,070
- Petition for Certiorari and Prohibition
- Relief Sought
- Declare RA 9716 unconstitutional for violating Article VI, Section 5(3) of the 1987 Constitution (minimum population of 250,000 per legislative district)
- Restrain COMELEC from implementing RA 9716
- Contentions
- New 1st District’s population (176,383)
- Constitutional Commission’s original use of a 250,000 “population constant” as baseline for legislative districts
Issues:
- Procedural Issues
- Proper Remedy – Whether Certiorari and Prohibition under Rule 65 is the appropriate remedy for constitutional challenge to a statute
- Locus Standi – Whether petitioners, as public officers, taxpayers, and citizens, have standing to question RA 9716
- Substantive Issues
- Constitutional Requirement – Whether the 250,000-minimum population requirement applies to the creation or reapportionment of legislative districts in a province
- Compliance with Section 5, Article VI – Whether RA 9716 violates requirements of contiguous, compact, and adjacent territory and the population standard for legislative districts
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)