Case Digest (G.R. No. 209535) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Agripino A. de Guzman, Jr. et al. v. Commission on Elections (G.R. No. 129118, July 19, 2000), petitioners Agripino A. de Guzman, Jr., Narciso M. Arabe, Leticia T. Endoma and over one hundred other city and municipal election officers challenged the validity of Section 44 of Republic Act No. 8189, the “Voter’s Registration Act of 1996.” Enacted on June 10, 1996 and approved on June 11, 1996, RA 8189’s Section 44 provides that no election officer may serve longer than four years in the same city or municipality and mandates automatic reassignment thereafter. Pursuant to this provision, the Commission on Elections (COMELEC) adopted Resolution Nos. 97-0002 and 97-0610 and issued several directives reassigning the petitioners to new stations outside their original congressional districts. Aggrieved, the petitioners brought a petition for certiorari and prohibition with prayer for injunctive relief directly to the Supreme Court, asserting that Section 44 violated equal protection, Case Digest (G.R. No. 209535) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Enactment of Republic Act No. 8189
- RA 8189, “The Voter’s Registration Act of 1996,” was enacted on June 10, 1996, and approved on June 11, 1996.
- Section 44 provides that no Election Officer shall hold office in the same city or municipality for more than four years and mandates automatic reassignment outside the original congressional district thereafter.
- Implementation by the Commission on Elections (COMELEC)
- To carry out Section 44, the COMELEC issued Resolution Nos. 97-0002 and 97-0610.
- Pursuant thereto, the COMELEC issued several directives reassigning petitioners (City and Municipal Election Officers) to new stations.
- Filing of Petition
- Petitioners sought certiorari and prohibition before the Supreme Court, with an urgent prayer for a temporary restraining order and preliminary injunction.
- They challenged Section 44 on six constitutional grounds:
- Violation of the Equal Protection Clause
- Infringement of Security of Tenure
- Deprivation of Property without Due Process
- Undermining COMELEC’s constitutional authority
- Breach of the Single Subject Rule and Title requirement
- Noncompliance with the Three-Readings and distribution rule
Issues:
- Does Section 44 of RA 8189 violate the Equal Protection Clause?
- Does Section 44 infringe the Security of Tenure of civil servants?
- Does Section 44 constitute a deprivation of property without due process?
- Does Section 44 undermine the COMELEC’s constitutional authority to appoint, designate, reassign, and transfer its officials?
- Does Section 44 contravene the Single-Subject Rule and Title requirement of Article VI, Section 26(1)?
- Was Section 44 enacted in violation of the Three-Readings Rule and distribution requirement of Article VI, Section 26(2)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)