Case Digest (G.R. No. L-32322-23) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On October 10, 2022, President Ferdinand R. Marcos Jr. signed Republic Act No. 11935, which (1) postponed the synchronized barangay and Sangguniang Kabataan elections (BSKE) originally scheduled for December 5, 2022 to the last Monday of October 2023 and (2) authorized incumbent barangay and SK officials to hold over “until their successors shall have been duly elected and qualified.” Two consolidated petitions—G.R. No. 263590 by Atty. Romulo B. Macalintal and G.R. No. 263673 by Atty. Alberto N. Hidalgo et al.—challenged RA 11935 for violating the people’s right of suffrage, effecting an unconstitutional transfer of COMELEC funds, and amounting to a legislative appointment of local officials. The Office of the Solicitor General defended the Law as within Congress’s plenary power to regulate elections and distinct from the COMELEC’s administrative, quasi-judicial, and quasi-legislative powers under Article IX-C. In response, the COMELEC suspended preparations for the December 202 Case Digest (G.R. No. L-32322-23) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Petitions
- G.R. No. 263590 – Atty. Romulo B. Macalintal filed a Petition for certiorari, prohibition, and prohibition with urgent prayer to compel COMELEC to hold the December 5, 2022 BSKE.
- G.R. No. 263673 – Atty. Hidalgo et al. filed a Petition for certiorari, prohibition, and mandamus to enjoin enforcement of RA 11935.
- Enacted Law – RA 11935 (October 10, 2022)
- Section 1 – Rescheduled synchronized barangay and SK elections to last Monday of October 2023 and every three years thereafter.
- Section 3 – Hold-over: all incumbent barangay and SK officials remain in office until their successors are duly elected and qualified.
- Procedural History
- Both petitions consolidated in October 2022; COMELEC, Executive Secretary, and legislative leaders ordered to comment.
- Oral arguments held October 21, 2022; memoranda later submitted.
Issues:
- Constitutionality of RA 11935
- Whether Congress may postpone barangay and SK elections by law or whether that power is exclusively administrative to COMELEC under Section 5 of the Omnibus Election Code (OEC).
- Whether RA 11935 violates due process by lacking a legitimate state interest and unduly infringing the right of suffrage.
- Whether its enactment was tainted by grave abuse of discretion.
- Effect of declaring RA 11935 unconstitutional on election schedule and incumbent hold-over.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)