Case Digest (G.R. No. 146511)
Facts:
In Fariñas v. Executive Secretary (G.R. No. 147387) and Salapuddin v. Commission on Elections (G.R. No. 152161), decided on December 10, 2003, en banc, petitioners Rodolfo C. Fariñas, Manuel M. Garcia, Francis G. Escudero, Agapito A. Aquino and Congressman Gerry A. Salapuddin—each a member of the House of Representatives and, in the first petition, also taxpayers—filed petitions under Rule 65 of the Rules of Court. They sought to declare Section 14 of Republic Act No. 9006 (the Fair Election Act) unconstitutional to the extent that it repeals Section 67 of Batas Pambansa Blg. 881 (the Omnibus Election Code). Section 67 had provided that any elective official running for an office other than the one he permanently holds “shall be considered ipso facto resigned” upon filing his certificate of candidacy. The respondents included the Executive Secretary, the Commission on Elections, the Speaker of the House, and other congressional officers. Petitioners argued that Section 14 of RACase Digest (G.R. No. 146511)
Facts:
- Parties and Proceedings
- Petitioners: Rodolfo C. Fariñas, Manuel M. Garcia, Francis G. Escudero, Agapito A. Aquino, and Gerry A. Salapuddin—Members of the House of Representatives (Minority), taxpayers, and registered voters—filed petitions for certiorari and prohibition under Rule 65, challenging Republic Act No. 9006 (“Fair Election Act”).
- Respondents: Executive Secretary; Commission on Elections (COMELEC); Hon. Feliciano R. Belmonte, Jr., Speaker of the House; Secretary of the Interior and Local Government; Secretary of the Senate; Secretary General of the House.
- Statutory Background
- R.A. 9006 consolidated House Bill No. 9000 and Senate Bill No. 1742 to regulate “fair election practices,” lift bans on media use in campaigns, and eliminate unfair practices.
- Section 14 of R.A. 9006 repealed Section 67 of Batas Pambansa Blg. 881 (Omnibus Election Code), which provided that elective officials (except President/Vice-President) running for another office are ipso facto resigned upon filing of candidacy. Section 66 (appointive officials) was retained.
- Petitioners’ Contentions
- Section 14 is an unconstitutional rider violating Art. VI, Sec. 26(1) (one subject-one title).
- The repeal breaches equal protection by favoring elective over appointive officials.
- Section 16’s “effectivity upon approval” clause violates due process (publication requirement).
- Legislative enactment was tainted by procedural irregularities (multiple bicameral committees, unsigned reports, substituted effectivity clause), warranting nullification of R.A. 9006 in its entirety.
- Respondents’ Defense
- Petitioners lack standing; no personal injury as taxpayers.
- The “enrolled bill” doctrine bars inquiry into legislative process.
- The title of R.A. 9006 is broad enough to cover the repeal of Section 67; repeal is germane to fair election practices.
- Classification between elective (Section 67) and appointive (Section 66) officials is constitutionally reasonable.
- Effectivity clause does not deprive any person of life, liberty, or property; publication and due process issues are premature.
Issues:
- Standing
- Whether Members of Congress, as taxpayers and voters, have locus standi to question R.A. 9006.
- Merits
- Whether Section 14 of R.A. 9006 is an unconstitutional rider violating the one subject-one title rule.
- Whether the repeal of Section 67 alone violates the equal protection clause.
- Whether alleged procedural irregularities in enacting R.A. 9006 justify invalidating the law under the enrolled bill doctrine.
- Whether Section 16’s immediate-effect clause violates due process by omitting required publication.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)