Title
League of Cities of the Philippines vs. Commission on Elections
Case
G.R. No. 176951
Decision Date
Jun 28, 2011
The Supreme Court upheld the constitutionality of 16 Cityhood Laws, ruling they were validly enacted, did not violate the Constitution, and respected legislative prerogatives, despite multiple reversals.

Case Digest (G.R. No. 176951)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
  • Petitioners
    • League of Cities of the Philippines (LCP), represented by National President Jerry P. Treaas
    • City of Calbayog, represented by Mayor Mel Senen S. Sarmiento
    • Jerry P. Treaas, in his personal capacity as taxpayer
  • Respondents
    • Commission on Elections (COMELEC)
    • Various municipalities formerly seeking conversion into cities (Baybay, Bogo, Catbalogan, Tandág, Borongan, Tayabas, Lamitan, Tabuk, Bayugan, Batac, Mati, Guihulngan, Cabadbaran, Carcar, El Salvador, Naga)
    • Department of Budget and Management (DBM)
  • Subject Matter
    • Constitutionality of sixteen (16) Cityhood Laws (R.A. Nos. 9389, 9390, 9391, 9392, 9393, 9394, 9398, 9404, 9405, 9407, 9408, 9409, 9434, 9435, 9436, 9491)
    • Alleged violation of Article X, Sections 6 and 10 (immu­tability of judgment, res judicata, Local Government Code requirements, equal protection and just share in national taxes)
  • Procedural History
  • Decision dated 15 February 2011
    • SC Division upheld the constitutionality of the sixteen Cityhood Laws
  • Ad Cautelam Motion for Reconsideration (filed 8 March 2011)
    • Denied by Resolution dated 12 April 2011, declared final
  • Motion for Leave to File Motion for Reconsideration (dated 29 April 2011)
    • Attached “second” Motion for Reconsideration of the 12 April 2011 Resolution
  • Respondents’ Motion for Entry of Judgment (dated 9 May 2011)

Issues:

  • Procedural Validity
  • Whether the April 29 2011 Motion for Reconsideration is a prohibited second motion under Rule 51, Section 2 of the Rules of Court and the Supreme Court’s Internal Rules.
  • Identity of Issues
  • Whether the new Motion for Reconsideration presents issues materially different from those already resolved in the Ad Cautelam motion.
  • Finality of Ruling
  • Whether the Resolution of 12 April 2011 became final upon the Court’s express declaration.
  • Appropriate Relief
  • Whether to deny the petitioners’ Motion for Reconsideration.
  • Whether to grant the respondents’ Motion for Entry of Judgment.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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