Facts:

The case of Vice Mayor Shirlyn L. Baas-Nograles, et al. vs. Commission on Elections (G.R. No. 246328) arose from the Commission on Elections (COMELEC) Resolution No. 10524, dated April 11, 2019, which suspended the elections for the newly reapportioned First Legislative District of South Cotabato, including General Santos City, scheduled for May 13, 2019. This suspension resulted from the enactment of Republic Act No. (R.A.) 11243 on March 11, 2019, signed by President Rodrigo Duterte, which created a lone legislative district for General Santos City and aimed to commence its elections during the next national elections after the law's effectivity. Since R.A. 11243 became effective on April 4, 2019, just over a month before the elections, it was impossible for COMELEC to adjust electoral configurations in time due to operational constraints such as the filing of candidacies and printing of ballots.

In COMELEC's Resolution, it declared that if elections were held, all vot

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Facts:

Statutory and Legislative Background

• On March 11, 2019, President Rodrigo Roa Duterte signed Republic Act No. 11243, which reapportioned the First Legislative District of South Cotabato by creating the lone legislative district of General Santos City.
• Section 1 of RA 11243 stipulated that the creation of the lone district was “to commence in the next national and local elections after the effectivity of this Act.”
• RA 11243 took effect on April 4, 2019, leaving a narrow window before the May 13, 2019 general elections.
• The law also provided that the incumbent Representatives of the First and Second Legislative Districts would continue in office “until new representatives shall have been elected and qualified.”

COMELEC’s Actions and Resolution

• In response to RA 11243, the Commission on Elections (COMELEC) was mandated to issue rules for its implementation.
• On April 11, 2019, COMELEC issued Resolution No. 10524.
• Section 3 of the Resolution noted that the electoral data for the representative for the First Legislative District (which included General Santos City) had been configured into the automated election system reflecting the old district setup.
• It detailed operational and logistical constraints that rendered a last-minute revision of the electoral configuration unfeasible; these included:
• Filing of Certificates of Candidacy for the newly created districts;

ii. Finalization of the candidates’ list; iii. Finalization and printing of the ballot face.

Petitioners’ Arguments and Grievances

• Petitioners, led by Vice Mayor Shirlyn L. BaAas-Nograles and her co-petitioners, challenged the validity of COMELEC Resolution No. 10524 on several grounds:
• The suspension of the May 13, 2019 election for the First Legislative District violated Republic Act No. 7166, which mandates that elections for the House of Representatives be held on the second Monday of May every three years.
• The scheduling of a “special” election within six months contravened the intent of RA 11243, which implied that the reapportionment should not affect the 2019 elections but rather commence in the next regular electoral cycle (i.e., on the second Monday of May 2022).
• The classification of votes cast for the First Legislative District as stray would result in a period with no duly elected representative, effectively disenfranchising the voters.
• Allowing the incumbent to remain in office beyond the term would extend his tenure without securing the voters’ mandate.
• The petitioners also raised a comparative argument, noting that similar legislative adjustments (as seen in RA 11257 for Cebu and RA 11198 for Southern Leyte) resulted in timely proclamations for the winning candidates, thus questioning the disparate treatment in South Cotabato.
• Petitioners sought several forms of relief:
• Granting of the petition;
• Proclamation of BaAas-Nograles as the winning candidate based on the majority vote;
• Issuance of a Status Quo Ante Order to restore the electoral rights of the voters in the First Legislative District for the May 13, 2019 elections.

Development of the Election and Subsequent Proceedings

• Despite the pending petition, the May 13, 2019 elections were held.
• In the election for the First Legislative District, Vice Mayor BaAas-Nograles garnered 194,929 out of 284,351 votes.
• However, pursuant to Section 3 of the COMELEC resolution, all votes cast for the district were treated as stray.
• Following the election, BaAas-Nograles filed multiple manifestations seeking relief and the enforcement of her right to be proclaimed as the duly elected representative.

Issue:

Jurisdictional and Statutory Authority

• Whether COMELEC, under its constitutional and statutory powers, validly suspended the scheduled May 13, 2019 election for the First Legislative District of South Cotabato.
• Whether COMELEC had the authority to reschedule the election “within six (6) months from May 13, 2019” in light of the provisions of RA 11243 and RA 7166.

Constitutional and Legislative Consistency

• Whether the suspension of the election and the treatment of votes as stray contravened the constitutional mandate to hold elections on the second Monday of May, as provided in Section 8, Article VI of the 1987 Constitution.
• Whether RA 11243’s provision that the reapportionment should commence in the next regular election confirms that the 2019 election should not have been affected.

Practical and Democratic Considerations

• Whether declaring votes as stray and postponing the election disenfranchises voters by leaving the district without representation for an extended period.
• Whether the differential treatment compared to similar legislative reapportionment in other provinces (e.g., Cebu and Southern Leyte) undermines the consistency of electoral administration.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)