Title
Occena vs. Commission on Elections
Case
G.R. No. 56350
Decision Date
Apr 2, 1981
Petitioners challenged 1973 Constitution's validity, Interim Batasang Pambansa's authority to propose amendments, and ratification process; SC upheld Constitution, dismissed petitions.

Case Digest (G.R. No. 208393)
Expanded Legal Reasoning Model

Facts:

  • Nature of the Actions and Parties
    • Two petitions for prohibition filed by Samuel C. Occena (G.R. No. 56350) and Ramon A. Gonzales et al. (G.R. No. 56404) as taxpayers.
    • Respondents: Commission on Elections, Commission on Audit, National Treasurer, Director of Printing.
  • Chronology of Proceedings
    • Petitions filed on March 6 and March 12, 1981; respondents required to answer by March 20 and 23, respectively.
    • Answers and comments filed; cases set for oral argument on March 26, 1981; submission of supplemental data; deemed submitted.
  • Subject Matter of the Challenge
    • Validity of Batasang Pambansa Resolutions Nos. 28, 104 and 106 (1981) proposing amendments to the 1973 Constitution.
    • Petitioners contend (a) the 1973 Constitution is not the fundamental law, (b) the resolutions exceed the Interim Batasang Pambansa’s authority, (c) procedural requirements for proposing and submitting amendments were violated.

Issues:

  • Constitutional Status
    • Is the 1973 Constitution in force and binding as the fundamental law of the land?
  • Authority to Propose Amendments
    • Does the Interim Batasang Pambansa have the constitutional power to propose amendments to the 1973 Constitution?
    • If so, what vote threshold is required?
  • Procedural Compliance
    • Were the challenged resolutions approved by the requisite number of votes?
    • Was the proposed plebiscite properly scheduled and was there fair submission to the people?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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