Case Digest (G.R. No. L-18684)
Facts:
Lamberto Macias, et al. v. The Commission on Elections, et al., G.R. No. L-18684, September 14, 1961, the Supreme Court En Banc, Bengzon, C.J., writing for the Court. Petitioners were four members of the House of Representatives (from Negros Oriental, Misamis Oriental, and Bulacan) and the provincial governor of Negros Oriental; respondents were the Commission on Elections, the National Treasurer and other officers charged with implementing Republic Act No. 3040 (the 1961 apportionment law). Petitioners sought to enjoin respondent officials from implementing RA 3040 on the ground that it violated constitutional requirements governing legislative apportionment.Petitioners alleged three principal grounds: (a) RA 3040 was passed without furnishing Members printed final copies of the bill at least three calendar days prior to passage as required by the Constitution; (b) the apportionment was enacted more than three years after the return of the last census enumeration; and (c) the statute apportioned seats among provinces without regard to the number of inhabitants, producing gross inequalities. Respondents admitted some facts but defended the Act’s constitutionality, invoked the enrolled-bill presumption, and asserted that the Director of the Census had submitted a population report on November 23, 1960 that served as the basis for the bill.
The Court issued a short resolution on August 23, 1961, finding that RA 3040 “clearly violates the said constitutional provision in several ways” (pointing to specific mismatches between population and seats) and, without dissent, granted the injunction prayed for by petitioners and ordered that no bond be required. After motions for reconsideration, the Court issued the present full opinion to explain its conclusions, addressing petitioners’ standing, the printed-bill req...(Pro-only)
Issues:
- Do petitioners have legal personality (standing) to challenge the validity of Republic Act No. 3040?
- Did the Court decide whether the failure to distribute printed final copies of the bill three days before passage invalidates RA 3040?
- Was RA 3040 enacted more than three years after the return of the last enumeration so as to violate the Constitution?
- Did RA 3040 violate the constitutional command that members of the House be apportioned among the provinces “as nearly as may be according to the number of their respec...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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