Case Digest (G.R. No. 93054)
Facts:
The PETITIONERS, composed of Cordillera officials and residents, challenged actions taken after the January 30, 1990 plebiscite held under Republic Act No. 6766 in Benguet, Mountain Province, Ifugao, Abra, Kalinga-Apayao and Baguio City, in which only Ifugao voted to approve the Organic Act. The RESPONDENTS issued Resolution No. 2259 (COMELEC, Feb. 14, 1990) and the Secretary of Justice issued a memorandum concluding that Ifugao alone constituted the Cordillera Autonomous Region; Congress enacted Republic Act No. 6861 (Mar. 8, 1990); Executive memoranda and Administrative Order No. 160 followed, and the petitioners sought judicial relief to annul those acts and preserve Executive Order No. 220.
Issues:
- Can the province of Ifugao alone legally and validly constitute the Cordillera Autonomous Region under Article X, Section 15, 1987 Constitution and Republic Act No. 6766?
- Are Resolution No. 2259, the February 14, 1990 memorandum of the Secretary of Justice, the February 5, 1990 memorandum of the Executive Secretary, Administrative Order No. 160, and Republic Act No. 6861 valid and enforceable insofar as they uphold creation of the autonomous region?
Ruling:
The petition was GRANTED. Resolution No. 2259, the February 14, 1990 memorandum of the Secretary of Justice, the February 5, 1990 memorandum of the Executive Secretary, Administrative Order No. 160, and Republic Act No. 6861 were declared null and void insofar as they upheld the creation of an autonomous region consisting of only the province of Ifugao. Executive Order No. 220 was declared to remain in force until properly repealed or amended.
Ratio:
The Court held that Article X, Section 15, 1987 Constitution contemplates autonomous regions composed of provinces, cities, municipalities, and geographical areas in the plural, and that the ordinary meaning of "region" denotes more than one constituent unit. The provisions of Republic Act No. 6766 presuppose a multi-unit region (regional government, assembly districts, planning boards, commissions) and thus a single-province CAR would be impracticable, contrary to the Organic Act, and inconsistent with the Constitution; the Court found Abbas, et al. v. COMELEC inapposite to the single-province question.
Doctrine:
- Article X, Section 15, 1987 Constitution requires autonomous regions to consist of multiple constituent units, not a sole province.
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