Title
Ordillo vs. Commission on Elections
Case
G.R. No. 93054
Decision Date
Dec 4, 1990
A plebiscite approved CAR only in Ifugao; SC ruled a single province cannot constitute an autonomous region, nullifying related government actions.

Case Digest (G.R. No. 93054)
Expanded Legal Reasoning Model

Facts:

  • Plebiscite and Voting Results
    • On January 30, 1990, pursuant to Republic Act No. 6766, the provinces of Benguet, Mountain Province, Ifugao, Abra, Kalinga-Apayao, and the city of Baguio held a plebiscite on the Organic Act for the Cordillera Autonomous Region (CAR).
    • Only Ifugao voted in favor by a slim majority of 5,889 votes; the other units rejected the measure by 148,676 votes.
  • Administrative and Legislative Actions
    • February 14, 1990: COMELEC Resolution No. 2259 declared that, since only Ifugao voted “yes,” that province alone ratified the Organic Act. Simultaneously, the Secretary of Justice issued a memorandum confirming that Ifugao “alone, legally and validly constitutes the CAR.”
    • February 5, 1990: The Executive Secretary authorized winding up of the Cordillera Executive Board and Assembly created under E.O. No. 220.
    • March 8, 1990: Congress passed Republic Act No. 6861 setting regional elections in the CAR of Ifugao for March 1991.
    • March 9 and March 30, 1990: Petitioners filed with COMELEC to declare non-ratification of the Organic Act; on March 30, the President issued Administrative Order No. 160 abolishing the Cordillera Executive Board, Assembly, and related offices.
  • Petitioners’ Claims and Prayer
    • Petitioners, comprising regional officials and residents, argued that under the Constitution and RA 6766 an autonomous region must consist of multiple constituent units, not a single province.
    • They prayed for:
      • Nullification of COMELEC Res. 2259, the Justice and Executive Secretary memoranda, A.O. 160, and RA 6861, and enjoining their implementation and spending;
      • Declaration that E.O. 220 remains in force until a valid organic law is enacted and ratified.

Issues:

  • Can a single province (Ifugao) validly and legally constitute the Cordillera Autonomous Region under the 1987 Constitution and RA 6766?
  • Are COMELEC Resolution No. 2259, the Secretary of Justice and Executive Secretary memoranda, Administrative Order No. 160, and Republic Act No. 6861 valid, or must they be annulled?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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