Facts:
Petitioners, including members of the House of Representatives and a provincial governor, challenged the constitutionality of Republic Act 3040, which apportioned representative districts in the Philippines. They argued that the law violated constitutional provisions in three ways:
- It was passed without printed final copies of the bill being furnished to House members at least three calendar days prior to its passage.
- It was approved more than three years after the last population census.
- It apportioned districts without regard to the number of inhabitants in the provinces.
- Personality of Petitioners:
The petitioners, representing provinces such as Negros Oriental, Misamis Oriental, and Bulacan, claimed their provinces were discriminated against in the apportionment. For example:
- Misamis Oriental (387,839 inhabitants) was given one district, while Cavite (379,902 inhabitants) received two.
- Negros Oriental (598,783 inhabitants) and Bulacan (557,691 inhabitants) were allotted two districts each, while Albay (515,961 inhabitants) received three.
- Printed Bill Requirement:
Petitioners presented certificates from the Secretary of the House of Representatives showing that no printed copies of the bill were distributed three days before its passage on May 10, 1961, and no presidential certificate of urgency was issued.
The apportionment was based on a preliminary population report submitted by the Director of the Census on November 23, 1960. Petitioners argued that this report was not final and could not legally serve as the basis for apportionment.
- Apportionment Discrepancies:
The law was criticized for disproportionate representation. For example:
- Cebu (smaller population) received seven representatives, while Rizal (larger population) received four.
- Manila (smaller population) received four representatives, while Cotabato (larger population) received three.
Issues:
- Whether Republic Act 3040 violated the constitutional requirement that printed copies of bills be furnished to House members at least three days before passage.
- Whether the apportionment of districts under Republic Act 3040 violated the constitutional mandate of proportional representation based on population.
- Whether the petitioners had the legal standing to challenge the constitutionality of the law.
Ruling:
Ratio: