G.R. No. 77429 - Santos vs. People

Petitioners: Four members of the House of Representatives from Negros Oriental, Misamis Oriental, and Bulacan, and the Provincial Governor of Negros Oriental, suing in their own behalf and on behalf of residents of their provinces.
Respondents: Commission on Elections (COMELEC), the National Treasurer, and other officials tasked with implementing Republic Act No. 3040 (RA 3040).
Relief sought: Prohibition and injunction to prevent implementation of RA 3040 on the ground that it is unconstitutional and void.

RA 3040: A reapportionment law allocating the 120 seats of the House of Representatives among provinces and cities.
Pertinent constitutional provisions:

Apportionment clause: Members of the House “shall be apportioned among the several provinces as nearly as may be according to the number of their respective inhabitants.”
Census clause: Congress “shall, by law, make an apportionment within three years after the return of every enumeration, and not otherwise.”
Printed-bill clause: “No bill shall be passed by either House unless it shall have been printed and copies thereof in its final form furnished its Members at least three calendar days prior to its passage, except when the President shall have certified to the necessity of its immediate enactment.”

Procedural violation: The House allegedly passed the bill without furnishing members printed final copies at least three calendar days before passage, without any presidential certification of urgency.
Timeliness: The law was allegedly enacted more than three years after the return of the last census.
Substantive violation: The apportionment disregarded the constitutional requirement of proportional representation by inhabitants, resulting in systematic underrepresentation of certain provinces (including those of petitioners) and overrepresentation of others.

Presumption of constitutionality: RA 3040 is presumed valid; respondents were merely complying with their official duties.
Personality: Petitioners allegedly lacked standing to sue.
Enrolled-bill rule: A duly certified copy of the law conclusively presumes compliance with constitutional legislative procedures (including the printed-bill requirement), rendering contrary evidence inadmissible.
Census basis: The Director of the Census submitted an official population report in November 1960 which formed the basis of the bill.
Substantive compliance: RA 3040 allegedly substantively complied with proportional representation “as nearly as may be.”

House records: Certificates of the House Secretary showing no printed final copies were distributed three days prior to passage on May 10, 1961, and no presidential certification of urgency was received.
Census letter: The Director of the Census’ November 23, 1960 letter submitting a “preliminary” count, described as subject to revision but “official for all purposes” until final report; population census part of a broader 1960 series (population, housing, agriculture, economics).
Population-Seat Disparities: Multiple instances where provinces with fewer inhabitants received the same or more representatives than more populous provinces.

After hearing and memoranda, the Court issued on August 23 a resolution enjoining implementation of RA 3040, finding clear violations of the constitutional mandate of apportionment by inhabitants; no bond required.
The Court reserved fuller discussion of other issues (including the printed-bill clause and census issues) for a subsequent extended opinion; respondents moved for reconsideration.

Cebu received 7 members, while Rizal, with a bigger population, got 4.
Manila received 4 members, while Cotabato, with a bigger population, got 3.
Pangasinan, with fewer inhabitants than both Manila and Cotabato, received 5 members (more than either).
Samar (871,857) received 4 members, while Davao (903,224) got 3.
Bulacan (557,691) received 2 members, while Albay (about 515,9xx) got 3.
Misamis Oriental (387,839) received 1 member, while Cavite (379,904) got 2.
Mountain Province received 3, whereas Isabela, Laguna, and Cagayan, each with more inhabitants, received 2 each.
Capiz, La Union, and Ilocos Norte received 2 each, while Sulu, with more inhabitants, got 1.
Leyte (967,323) received 4, while Iloilo, with fewer inhabitants (966,145), received 5.

The Supreme Court permanently enjoined enforcement of RA 3040 and declared it unconstitutional and void for violating the constitutional principle of apportionment by inhabitants.
The Court expressed confidence that Congress would enact remedial legislation consistent with constitutional mandates.

Whether petitioners (as citizens, voters, legislators, and a governor of allegedly underrepresented provinces) have standing to challenge RA 3040.

Whether persons deprived of constitutionally required electoral equality may sue to test an apportionment act.

Whether RA 3040 is invalid for failure to comply with the constitutional “printed final copy furnished three days prior” requirement.

Whether the enrolled-bill doctrine forecloses judicial inquiry into compliance with the printed-bill requirement.

Whether RA 3040 was enacted “within three years after the return of every enumeration” and whether any noncompliance invalidates the statute.

Whether Congress could rely on a “preliminary,” potentially revisable population count, represented as “official for all purposes,” as a valid “return of the enumeration” for apportionment.

Whether RA 3040 violates the constitutional command that representatives be apportioned among provinces “as nearly as may be according to the number of their respective inhabitants.”

Whether the constitutionality of an apportionment act is a political question nonjusticiable by the courts.