Case Digest (G.R. No. 157013) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Macalintal v. Commission on Elections (G.R. No. 157013, July 10, 2003), petitioner Atty. Romulo B. Macalintal—an engaged taxpayer and member of the Philippine Bar—filed a Rule 65 petition before this Court against the Commission on Elections (COMELEC), Executive Secretary Alberto Romulo, and Budget Secretary Emilia Boncodin. He assailed the constitutionality of several provisions of Republic Act No. 9189 (The Overseas Absentee Voting Act of 2003), which Congress enacted to implement Article V, Section 2 of the 1987 Constitution by providing a system for overseas absentee voting and appropriating necessary funds. Petitioner claimed standing as a taxpayer to halt the expenditure of public funds under the challenged sections on grounds that they infringe constitutional limits on residency qualifications for suffrage, delegate to COMELEC and a joint congressional committee powers reserved to Congress and violate the independence of a constitutional commission. There were no pr Case Digest (G.R. No. 157013) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition and Respondents
- Atty. Romulo B. Macalintal filed a petition for certiorari and prohibition.
- He challenged provisions of Republic Act No. 9189 (Overseas Absentee Voting Act of 2003).
- Respondents: Commission on Elections (COMELEC), Executive Secretary, Budget Secretary.
- Challenged Provisions of RA 9189
- Section 5(d): Permits immigrants or permanent residents abroad to register by affidavit of intent to return within three years.
- Section 17.1: Allows voting by mail subject to Joint Congressional Oversight Committee (JCOC) approval.
- Section 18.5: Empowers COMELEC to proclaim winning candidates despite delayed or impossible overseas voting.
- Sections 19 & 25: Require COMELEC’s implementing rules and regulations (IRR) to be reviewed, revised, amended, and approved by the JCOC.
- Petitioner’s Standing and Legal Interest
- Petitioner as lawyer and taxpayer seeks to restrain unconstitutional use of public funds.
- Claims injury to public right and transcendent issues of voting and separation of powers.
Issues:
- Residency Requirement
- Does Section 5(d) permitting immigrant or permanent residents abroad to vote by affidavit violate the “reside in the Philippines” requirement in Section 1, Article V of the Constitution?
- Canvassing and Proclamation of President and Vice-President
- Does Section 18.5’s grant of power to COMELEC to proclaim winners contravene Congress’s exclusive power under Section 4, Article VII to canvass votes and proclaim the President and Vice-President?
- Independence of COMELEC and Legislative Veto
- Do Sections 17.1, 19, and 25, which subject COMELEC’s rulemaking and voting-by-mail procedures to review and approval by the JCOC, violate COMELEC’s constitutional independence under Article IX-A?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)