Facts:

• Petitioners Patricio Dumlao, Romeo B. Igot, and Alfredo Salapantan, Jr. filed a Petition for Prohibition with Preliminary Injunction and/or Restraining Order against the Commission on Elections (COMELEC).
• They sought to prevent COMELEC from implementing certain provisions of Batas Pambansa Blg. 51, 52, and 53, claiming these were unconstitutional.
• Patricio Dumlao, a former Governor of Nueva Vizcaya, had filed his certificate of candidacy for the same position in the upcoming January 30, 1980 elections.
• Romeo B. Igot and Alfredo Salapantan, Jr. were taxpayers and qualified voters.
• Dumlao specifically challenged Section 4 of Batas Pambansa Blg. 52, arguing it was discriminatory and violated the equal protection and due process guarantees of the Constitution.
• Igot and Salapantan, Jr. also questioned other provisions, including the term of office for local elective officials and the disqualification of candidates based on acts of disloyalty to the State.
• The petitioners argued these provisions were unconstitutional and sought their nullification.

Issue:

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Ruling:

1. The Supreme Court upheld the constitutionality of the first paragraph of Section 4 of Batas Pambansa Blg. 52, which disqualifies retired elective local officials over 65 from running for the same office.
2. The Court declared the provision that considers the filing of charges for acts of disloyalty as prim...(Unlock)

Ratio:

• The Court reasoned that the classification in Section 4 of Batas Pambansa Blg. 52 was based on reasonable and real differentiations.
• The law aimed to promote the emergence of younger blood in local governments, which was a legitimate state interest.
• The classification was not arbitrary or unreasonable, as it applied equally to all retired elective local officials over 65 who had received retirement benefits.
• The Court emphasized that the equal protection clause does not forbid all legal classifications but only those that are arbi...continue reading