Case Digest (G.R. No. L-21486) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In League of Cities of the Philippines v. Commission on Elections (G.R. Nos. 176951, 177499 & 178056, December 21, 2009), the League of Cities of the Philippines (LCP), the City of Iloilo represented by Mayor Jerry P. TreAas, the City of Calbayog represented by Mayor Mel Sarmiento, and Jerry TreAas as taxpayer (collectively, petitioners) filed consolidated petitions for prohibition in the Supreme Court en banc against the Commission on Elections (COMELEC) and sixteen municipalities (respondents). Each respondent municipality had its own cityhood law—Republic Act Nos. 9389, 9390, 9391, 9392, 9393, 9394, 9398, 9404, 9405, 9407, 9408, 9409, 9434, 9435, 9436, and 9491—converting it into a city. Petitioners challenged the constitutionality of these laws for allegedly contravening Section 10, Article X of the 1987 Constitution and the Equal Protection Clause, seeking to enjoin COMELEC from conducting plebiscites. On November 18, 2008, by a 6–5 vote, the Court en banc granted the petit Case Digest (G.R. No. L-21486) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Context
- Petitioners: League of Cities of the Philippines (LCP) represented by its National President Jerry P. Treñas, Cities of Iloilo and Calbayog, and Jerry P. Treñas as taxpayer.
- Respondents: Commission on Elections (COMELEC) and sixteen (16) municipalities in Leyte, Cebu, Samar, Surigao del Sur, Eastern Samar, Quezon, Basilan, Kalinga, Agusan del Sur, Ilocos Norte, Davao Oriental, Negros Oriental, Agusan del Norte, Misamis Oriental.
- Petitioners-in-intervention: Twenty-five (25) other cities represented as LCP members.
- Legislative and Procedural Background
- During the 11th Congress (1998–2001), 57 cityhood bills were filed; 33 lapsed into law before RA 9009 took effect; 24 remained pending.
- RA 9009 (2001) amended Section 450 of the 1991 Local Government Code (LGC), raising the required average annual income for cityhood from ₱20 million to ₱100 million.
- Efforts to exempt the 24 pending municipalities via House Joint Resolutions in the 11th and 12th Congresses failed.
- In the 13th Congress (2004–2007), sixteen municipalities filed individual cityhood bills with exemption clauses from RA 9009’s income requirement; all lapsed into law between March and July 2007.
- Petitioners filed consolidated petitions for prohibition and declaratory relief to enjoin COMELEC plebiscites under the 16 cityhood laws, alleging unconstitutionality under Art. X, Sec. 10 (LGC as exclusive repository of criteria) and the equal protection clause.
- En Banc Proceedings and Motions
- November 18, 2008 Decision (6–5 vote): granted petitions; nullified the 16 cityhood laws.
- March 31, 2009 Resolution (6–6 split on first motion): denied reconsideration for lack of majority.
- April 28, 2009 Resolution (6–6 split on second motion): denied motion for reconsideration of the March 31 Resolution; directed entry of judgment.
- May 14, 2009 motion to amend the April 28 Resolution and June 2, 2009 Resolution: expunged as moot after entry of judgment.
- Respondent LGUs’ June 2009 motion for reconsideration of the June 2 Resolution remains unresolved.
Issues:
- Constitutional Validity under Article X, Section 10
- Whether the 16 cityhood laws, each exempting a municipality from RA 9009’s ₱100 million income requirement, violate the mandate that LGU creation “shall be in accordance with the criteria established in the Local Government Code.”
- Equal Protection Clause (Art. III, Sec. 1)
- Whether granting exemption to the 16 municipalities constitutes unreasonable classification and hostile discrimination against other municipalities and existing cities.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)