Case Digest (G.R. No. 118375) Core Legal Reasoning
Core Legal Reasoning
Facts:
On December 22, 1979, the Interim Batasan Pambansa enacted Batas Blg. 51, which, under Section 3, classified all chartered cities into “highly urbanized” (those with an annual regular income of not less than ₱40 million or, irrespective of income, the City of Baguio) and “component” cities. Highly urbanized city voters were expressly forbidden to participate in the election of provincial officials, whereas component city voters could do so only if their charters so provided. To implement this scheme for the January 30, 1980 local elections, the Commission on Elections (COMELEC) issued Resolution No. 1421, listing twenty cities (including Cebu City and Mandaue City) barred from voting for provincial officials. Cebu City, with an income of ₱51,603,147.64, qualified as highly urbanized despite its charter allowing provincial voting. Mandaue City, having an income below ₱40 million, was classified as a component city, but its charter (Republic Act No. 5519) prohibited its voters fro Case Digest (G.R. No. 118375) Expanded Legal Reasoning
Expanded Legal Reasoning
Facts:
- Antecedents and Parties
- Petition for prohibition and mandamus with prayer for preliminary injunction filed by Ramon B. Ceniza, Federico C. Cabilao, Jr., Nelson J. Rosal, and Alejandro R. Alinsug, as taxpayers and registered voters of Cebu City and Mandaue City, and members of the civic, non-partisan group D-O-E-R-S (Democracy or Extinction: Resolved to Succeed).
- Respondents are the Commission on Elections (COMELEC), Commission on Audit (COA), and the National Treasurer. The case was decided En Banc by the Supreme Court, through Justice Concepcion, Jr.
- Statutory and Constitutional Context
- On December 22, 1979, the Interim Batasang Pambansa enacted Batas Pambansa Blg. 51 (BP 51) calling local elections on January 30, 1980. Section 3 classified cities into:
- Highly urbanized cities (HUCs): any city with annual regular income of at least P40,000,000 at the approval of BP 51 (Baguio deemed HUC regardless of income).
- Component cities: all other cities considered components of their provinces.
- Voting rules under Section 3:
- Voters in HUCs “shall not participate nor vote in the election of the officials of the province in which the highly urbanized city is geographically located.”
- Voters in a component city “may be entitled to vote” for provincial officials if its charter so provides; otherwise, they do not vote in provincial elections.
- 1973 Constitution provisions relied upon:
- Art. II, Sec. 10: State shall guarantee and promote local autonomy.
- Art. XI, Sec. 4(1): Highly urbanized cities placed outside the supervisory authority of the province.
- Art. XI, Sec. 5: LGUs empowered to create sources of revenue and levy taxes, subject to law.
- Art. XI, Sec. 3: Plebiscite requirement for creation, division, merger, abolition, or boundary changes of LGUs (new requirement under the 1973 Constitution).
- Administrative Implementation
- COMELEC issued Resolution No. 1421 implementing BP 51, studying city charters and informing voters whether they could vote for provincial officials.
- It listed cities whose voters are not entitled to vote for provincial officials, including Cebu City and Mandaue City (among others such as Manila, Quezon, Pasay, Caloocan, Davao, Iloilo, Zamboanga, etc.), by reason either of HUC status or charter provisions.
- Particularized City Situations
- Cebu City:
- Had annual income of P51,603,147.64; classified as a highly urbanized city under BP 51.
- Its charter (C.A. No. 58 as amended by R.A. No. 3857) allows city voters to vote for provincial officials; however, BP 51’s HUC disqualification supersedes for purposes of the 1980 elections.
- Mandaue City:
- Not an HUC (income below P40,000,000) and thus a component city.
- Its charter (R.A. No. 5519, Sec. 96) expressly disallows city voters from voting for provincial officials (though residents may be candidates).
- Reliefs Sought and Grounds
- Petitioners sought to:
- Temporarily prohibit elections for provincial officials in provinces where the 18 (20 named) cities in COMELEC Resolution No. 1421 are located, particularly in Cebu; and temporarily prohibit the National Treasurer from releasing, and COA from auditing, funds for said elections.
- Alternatively, compel COMELEC to allow voters of Cebu City and Mandaue City to vote for provincial officials, with corresponding ballot spaces.
- Constitutional challenges:
- Against Section 3 of BP 51: alleged violation of equal protection and suffrage by using city income as the sole basis to bar HUC voters from provincial elections.
- Against R.A. No. 5519 (Mandaue Charter): alleged invalidity for lack of plebiscite ratification under the 1973 Constitution.
- Alleged political/gerrymandering motives: asserted that barring approximately 279,000 voters from Cebu City and Mandaue City from provincial elections prejudices the opposition in a known opposition bailiwick.
Issues:
- Whether Section 3 of BP 51, classifying cities (based on income) into HUCs whose voters cannot vote for provincial officials and component cities whose voters may vote if permitted by charter, violates:
- Equal protection of the laws.
- The constitutional right of suffrage and the principle of republicanism.
- Whether legislative variation among city charters, some allowing and others disallowing component city voters to participate in provincial elections, violates equal protection and the right of suffrage.
- Whether R.A. No. 5519 (Mandaue City Charter) is unconstitutional for lack of plebiscite ratification pursuant to the 1973 Constitution.
- Whether BP 51 and R.A. No. 5519 are invalid as alleged gerrymanders designed to confer unfair partisan advantage.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)