Case Digest (G.R. No. 134015) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves petitioners Hermie M. Herrera, Donabella T. Sorongon, Julio T. Tamayor, and Edeljulio R. Romero, taxpayers and residents of the Province of Guimaras, who filed a petition for certiorari seeking to annul and set aside Resolution No. 2950 issued by the Commission on Elections (COMELEC) on November 3, 1997. This Resolution amended earlier COMELEC resolutions concerning the districting and apportionment of Sangguniang Panlalawigan seats in Guimaras for the May 1998 elections. The petitioners specifically challenged the portion of the resolution that divided Guimaras into two provincial districts, allocating eight elective SP seats in total (3 seats in the first district and 5 in the second district).
The facts stem from the reclassification of Guimaras, which, upon the addition of two municipalities—San Lorenzo and Sibunag—passed a Resolution No. 68 dated March 25, 1996, requesting the COMELEC to divide the province into two districts. The Provincial Election Sup
Case Digest (G.R. No. 134015) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Context and Background
- Petitioners, taxpayers and residents of the Province of Guimaras, filed a petition for certiorari to annul and set aside Resolution No. 2950 promulgated by the Commission on Elections (COMELEC) on November 3, 1997.
- This resolution amended prior resolutions regarding the districting and adjustment of Sangguniang Panlalawigan and Panglungsod seats for the May 11, 1998 elections.
- The core issue concerned the division of the Province of Guimaras into two provincial districts and the apportionment of eight elective Sangguniang Panlalawigan seats.
- Initiation of District Division
- Due to the addition of two new municipalities, San Lorenzo and Sibunag, the Sangguniang Panlalawigan of Guimaras resolved to subdivide the province into two provincial districts.
- On March 25, 1996, the Sangguniang Panlalawigan passed Resolution No. 68, requesting the COMELEC to effectuate this division.
- The Provincial Election Supervisor conducted two consultative meetings on August 21 and October 2, 1996. Notified parties included elected provincial and municipal officials, barangay captains, kagawads, political party representatives, and other stakeholders.
- The meetings resulted in unanimous consensus by secret ballot for the division:
- First District: Municipalities of Jordan, Buenavista, and San Lorenzo with 3 Sangguniang Panlalawigan members
- Second District: Municipalities of Jordan, Nueva Valencia, and Sibunag with 3 members
- Official Recommendations and Reclassification
- On October 3, 1996, the Provincial Election Supervisor issued a memorandum recommending the division based on the consultative meeting results.
- On April 30, 1997, the Bureau of Local Government Finance reclassified Guimaras from a fifth-class to a fourth-class province pursuant to Memorandum Circular No. 97-1.
- Consequently, COMELEC issued Resolution No. 2950 on November 3, 1997, allotting eight Sangguniang Panlalawigan seats to Guimaras, divided into two provincial districts as follows:
| District | Population | Seats | Municipalities | |---------------|------------|-------|--------------------------------------------------| | 1st District | 56,218 | 3 | Buenavista (37,681), San Lorenzo (18,537) | | 2nd District | 70,252 | 5 | Jordan (25,321), Nueva Valencia (27,158), Sibunag (17,773) |
- Petitioners’ Assertions
- Petitioners challenged the division on these grounds:
- Districts are not compact, contiguous, or adjacent areas.
- Consultative meetings did not reflect the true sentiment of the voters due to lack of proper representation.
- The apportionment is inequitable.
- There is disparity in voter-to-Board Member ratios.
- Petitioners proposed an alternative redistricting:
| District | Voters | Seats | Municipalities | Ratio (voters per Board member) | |---------------|----------|-------|-------------------------------|---------------------------------| | 1st District | 63,002 | 4 | Buenavista, Jordan | 15,750 | | 2nd District | 63,468 | 4 | Nueva Valencia, Sibunag, San Lorenzo | 15,867 |
- Legal Provisions Governing the Issue
- Republic Act No. 6636: Allotment of elective members based on the provincial classification (fourth-class provinces have 8 members).
- Republic Act No. 7166: For provinces with only one legislative district, COMELEC shall divide into two districts, each comprising a compact, contiguous and adjacent territory, with seats equitably apportioned according to inhabitants.
- COMELEC Resolution No. 2131: Establishes rules for apportionment such as the use of the 1990 census, consultations, and compactness of districts.
Issues:
- Whether the COMELEC acted with grave abuse of discretion in dividing Guimaras into two provincial districts via Resolution No. 2950.
- Whether the districts as constituted satisfy the statutory requirements of being compact, contiguous, and adjacent territories.
- Whether the apportionment of eight Sangguniang Panlalawigan seats between the two districts is equitable and based on the proper population basis.
- Whether the consultative meetings genuinely represented the sentiment of the voters in Guimaras.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)