Case Digest (G.R. No. 176951) 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 and 178056 (En Banc, February 15, 2011), petitioners League of Cities of the Philippines (LCP), represented by its National President Jerry P. Treñas; the City of Calbayog, represented by Mayor Mel Senen S. Sarmiento; and Jerry P. Treñas in his personal capacity as taxpayer challenged the constitutionality of sixteen Republic Acts converting sixteen municipalities into component cities. The respondents include the Commission on Elections, the sixteen newly created cities (Baybay, Bogo, Catbalogan, Tandag, Borongan, Lamitan, Tayabas, Tabuk, Bayugan, Batac, Mati, Guihulngan, Cabadbaran, El Salvador, Carcar and Naga) and the Department of Budget and Management. LCP initially sought a writ of prohibition to enjoin the Commission on Elections from holding plebiscites required by those laws. In a Decision dated November 18, 2008, the Court en banc by a 6–5 vote struck down the Cityhood Laws for Case Digest (G.R. No. 176951) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Consolidation and Parties
- Three consolidated petitions (G.R. Nos. 176951, 177499, 178056) filed by petitioners League of Cities of the Philippines (LCP) represented by National President Jerry P. Treñas, City of Calbayog represented by Mayor Mel Senen S. Sarmiento, and Jerry P. Treñas in his personal capacity as taxpayer.
- Respondents: Commission on Elections (COMELEC); Department of Budget and Management (DBM); and sixteen municipalities whose conversion into component cities under various Republic Acts (the “Cityhood Laws”) was challenged—namely Baybay, Bogo, Catbalogan, Tandag, Borongan, Tayabas, Lamitan, Tabuk, Bayugan, Batac, Mati, Guihulngan, Cabadbaran, El Salvador, Carcar, and Naga.
- Subject Matter and Relief Sought
- Petitioners assailed the constitutionality of sixteen Republic Acts converting those municipalities into component cities, each Act containing an exemption clause from the income requirement then prescribed in Section 450 of the Local Government Code (LGC), as amended by R.A. 9009.
- They sought to enjoin COMELEC from conducting plebiscites under those Acts and to have the Cityhood Laws declared void.
- Procedural History
- November 18, 2008 – By a 6–5 vote, the Court En Banc granted the petitions, striking down the Cityhood Laws for violating Sections 10 and 6 of Article X of the Constitution and the equal protection clause.
- March 31, 2009 – First motions for reconsideration denied (7–5 vote); April 28, 2009 – Second motions for reconsideration denied (6–6 vote, entry of judgment).
- December 21, 2009 – By a 6–4 vote, the Court declared the Cityhood Laws constitutional.
- August 24, 2010 – En Banc Resolution by a 7–6 vote reinstated the November 18, 2008 decision; respondents filed motions for reconsideration.
- September 14, 2010 – Respondents filed a motion for reconsideration of the August 24, 2010 Resolution, leading to the present resolution.
Issues:
- Validity under Article X, Section 10
- Do the Cityhood Laws violate Article X, Section 10 by deviating from the criteria—particularly the income requirement—established in the LGC as amended by R.A. 9009?
- Are the exemption clauses invalid because they are not themselves embedded in the LGC?
- Violation of Equal Protection Clause and Article X, Section 6
- Do the Cityhood Laws infringe on the “just share” of existing cities in the Internal Revenue Allotment (IRA), breaching Article X, Section 6?
- Do the exemption clauses amount to an impermissible classification under the equal protection clause?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)