Case Digest (G.R. No. 180915) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On August 25 and 30, 2006, petitioners Raul L. Lambino and Erico B. Aumentado filed with the Commission on Elections (COMELEC) a “People’s Initiative” petition to amend the 1987 Constitution. They sought to modify Articles VI and VII—shifting the form of government from bicameral-presidential to unicameral-parliamentary—and add transitory provisions (Article XVIII). They submitted signature sheets allegedly bearing 6,327,952 registered voters (12% of all voters, with at least 3% per legislative district) and certificates of verification by local election officers. On August 31, 2006, the COMELEC dismissed the petition, invoking this Court’s Santiago v. COMELEC (1997) decision holding Republic Act 6735 (“Initiative and Referendum Act”) “inadequate” to implement a people’s initiative to amend the Constitution and permanently enjoining the COMELEC from entertaining such petitions. Petitioners and intervenors filed consolidated petitions for certiorari and mandamus before this Court Case Digest (G.R. No. 180915) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Signature-gathering and initiative petition
- February 15, 2006 – Raul L. Lambino, Erico B. Aumentado, ULAP, Sigaw ng Bayan and other groups began gathering signatures for a people’s initiative to amend the 1987 Constitution.
- August 25, 2006 – The “Lambino Group” filed a petition under Sections 5(b) and 5(c) and Section 7 of Republic Act No. 6735, claiming 6,327,952 signatures (12% of registered voters, 3% per district) verified by COMELEC registrars, to shift from a bicameral-presidential to a unicameral-parliamentary system.
- August 30, 2006 – Lambino Group filed an amended petition to correct certain transitory provisions.
- COMELEC resolution and Binay opposition
- August 31, 2006 – COMELEC en banc denied due course to Lambino Group’s petition, invoking Santiago v. COMELEC (336 Phil. 848), which held RA 6735 “inadequate” for constitutional initiative on amendments.
- Binay Group (G.R. No. 174299) filed a petition-cum-opposition, treating COMELEC’s verification of signatures and entertaining Lambino petition as contempt of the Santiago injunction.
- Parties and intervenors
- Supporting intervenors argued COMELEC abused discretion and Santiago is not binding beyond its parties.
- Opposing intervenors maintained Santiago binds COMELEC, and challenged Lambino Group’s standing, signature gathering, verification process, single-subject rule and the nature of proposed changes (revision vs. amendment).
- Supreme Court proceedings
- September 26, 2006 – Oral arguments before the Court on (a) compliance with Section 2, Article XVII (12% rule); (b) need to revisit Santiago; (c) COMELEC’s alleged abuse; (d) nature of changes (amendment vs. revision); and (e) single-subject rule.
- October 25, 2006 – Submission of memoranda and case submitted for resolution.
Issues:
- Does Lambino Group’s petition comply with Section 2, Article XVII of the Constitution (12% of registered voters, 3% per district)?
- Should the Court revisit Santiago v. COMELEC declaring RA 6735 inadequate to implement constitutional initiative?
- Did COMELEC commit grave abuse of discretion by denying due course to the Lambino petition?
- Is the people’s initiative power limited to amendments (not revisions) to the Constitution?
- Does Lambino Group’s petition violate the single-subject requirement under RA 6735?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)