G.R. No. 234491 - Duremdes vs. Jorilla

The case involves the Municipal Government of the Philippine Islands, on behalf of the Municipality of Cardona (plaintiff), versus the Municipality of Binangonan and others (defendants).
The dispute arose after the plaintiff amended its complaint following a demurrer on the original complaint, without alleging any new or additional facts, thereby leaving the case essentially in the same position as before the amendment.

The central issue involves section 1 of Act No. 1748, titled “An Act authorizing the adjustment of provincial and municipal boundaries and authorizing the change of capitals of provinces and subprovinces, as may be necessary from time to time to serve the public convenience and interest.”
This provision grants the Governor-General the authority to make immediate and detailed adjustments to political subdivisions (including enlarging, contracting, merging, separating, or renaming) by executive order whenever, in his judgment, public welfare requires such action.

The plaintiff contended that section 1 of Act No. 1748 violates the provisions of the Act of Congress of July 1, 1902, by delegating what it considered to be legislative functions to the executive, specifically to the Governor-General.
The argument was based on the premise that legislative powers, as provided by the Act of Congress, should not be transferred to the Governor-General, implying that such a delegation amounted to an unconstitutional abdication of legislative responsibility.

The section at issue empowers the Governor-General to adjust boundaries or change the government seat of any province, subprovince, municipality, township, or other political subdivision based solely on public interest considerations.
It further stipulates that in the creation of new political subdivisions, the Governor-General must appoint officers with specific powers and duties, fix their salaries, and ensure that these officers hold office either until successors are elected or appointed.
The designated changes are to take effect on a date fixed by the Governor-General’s executive order, thereby facilitating rapid response to evolving public needs and demographic shifts.

Whether the amendment of the complaint after the initial demurrer, which introduced no new facts, changes the substance or nature of the issues already addressed in the earlier stage of the proceedings.

Whether section 1 of Act No. 1748, by delegating the power to adjust municipal and provincial boundaries to the Governor-General, contravenes the statutory allocation of legislative functions as prescribed by the Act of Congress of July 1, 1902.

Whether such delegation represents an improper transference of legislative powers (an abdication of legislative functions by the legislature) or merely a transfer of certain administrative and detailed tasks necessary for effective governance.
Whether the power conferred is strictly administrative in nature, intended to address rapid and dynamic changes in political subdivisions, rather than to substitute for the deliberative process of the legislature.