Case Digest (G.R. No. 247610) Core Legal Reasoning Model
Facts:
In Cynthia S. Del Rosario, Federico N. Virgo, Jr., Renato V. Baladad, Beatriz A. Dioso, Corazon Manalon Davila, Loreta N. Alsa, Hiya I. Hassan, and John Vincent C. Colili vs. Commission on Elections, the Department of Budget and Management, the Provincial Government of Palawan, and the Provincial Treasurer of the Provincial Government of Palawan (G.R. No. 247610, March 10, 2020; decision February 14, 2022), petitioners challenged the constitutionality of Republic Act No. 11259 (RA 11259), which divided the Province of Palawan into Palawan del Norte, Palawan Oriental, and Palawan del Sur. Originating from House Bills Nos. 7413 and 8055 of the 17th Congress, RA 11259 was enacted on April 5, 2019 and published May 20, 2019. Section 51 provided for a plebiscite on the division, set for May 11, 2020, to be supervised by the Commission on Elections (COMELEC) at the expense of the then-existing provincial budget. Section 54 expressly disqualified the residents of Puerto Princesa City,
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Case Digest (G.R. No. 247610) Expanded Legal Reasoning Model
Facts:
- Petition and parties
- Petitioners: Cynthia S. Del Rosario, Federico N. Virgo, Jr., Renato V. Baladad, Beatriz A. Dioso, Corazon Manalon Davila (residents/voters of Puerto Princesa City) and Loreta N. Alsa, Hiya I. Hassan, John Vincent C. Colili (residents/voters of municipalities in Palawan).
- Respondents: Commission on Elections (COMELEC), Department of Budget and Management (DBM), Provincial Government of Palawan, Provincial Treasurer of Palawan.
- Legislative history and challenged provisions
- Republic Act No. 11259 (Charter of the Provinces of Palawan del Norte, Palawan Oriental, Palawan del Sur): passed March 10, 2020; signed into law April 5, 2019; published May 20, 2019.
- Section 51: creation of three provinces upon plebiscite approval (second Monday of May 2020); funding charged to Province of Palawan.
- Section 54: residents of Puerto Princesa City (a Highly Urbanized City) “shall not be qualified to vote” in the plebiscite or for provincial positions; transitional representation provisions.
- Petitioners challenge RA 11259 as unconstitutional and seek a writ of prohibition to enjoin the plebiscite and related expenditures.
Issues:
- Threshold issues
- Do petitioners have standing to challenge RA 11259?
- Is the petition premature given that many provisions of RA 11259 are contingent on plebiscite approval?
- Substantive issues
- Did the legislature violate the people’s right to public consultation by enacting RA 11259 without public hearings?
- Under Article X, Section 10 of the Constitution, are voters of Puerto Princesa City a “political unit directly affected” entitled to vote in the plebiscite?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)