G.R. No. 129754 - People's Initiative for Reform, Modernization and Action vs. Commission on Elections

Nature and Background of the Case
Private respondent Atty. Jesus S. Delfin filed on 6 December 1996 a “Petition to Amend the Constitution, to Lift Term Limits of Elective Officials, by People’s Initiative” before the Commission on Elections (COMELEC).
Delfin, a founding member of the Movement for People’s Initiative (later known as PIRMA), sought COMELEC’s assistance in:

Fixing time and dates for signature gathering nationwide;
Ordering publication of the petition and initiative in newspapers;
Instructing municipal election registrars to assist in establishing signature stations.

Delfin’s proposal aimed to amend Sections 4 and 7 of Article VI, Section 4 of Article VII, and Section 8 of Article X of the 1987 Constitution to lift term limits for elected officials.
The COMELEC promptly required Delfin to publish the petition and set hearings. Oppositions and interventions were filed by Senator Raul S. Roco, DIK, MABINI, IBP, and LABAN, among others.
Petitioners Miriam Defensor Santiago, Alexander Padilla, and Maria Isabel Ongpin filed a special civil action for prohibition against COMELEC and respondents, alleging the absence of an implementing law for people’s initiative on constitutional amendments.

The constitutional right to initiative on amendments requires an implementing law by Congress, which has not been passed;
R.A. No. 6735 (Initiative and Referendum Act) is inadequate and incomplete for implementing initiative on constitutional amendments;
COMELEC Resolution No. 2300 is ultra vires regarding constitutional initiative;
The Delfin petition lacks the required number of signatures;
Lifting term limits constitutes a constitutional revision, not a mere amendment, thus beyond the power of initiative;
No funds have been appropriated for conducting an initiative on amendments.

Private respondents and intervenors (including Delfin and the COMELEC) contended:

R.A. No. 6735 implements people’s initiative including constitutional amendments;
COMELEC Resolution No. 2300 validly promulgated rules for initiative on constitutional amendments;
Delfin’s petition solely seeks assistance to gather signatures and is not yet the formal initiatory petition;
Lifting term limits is an amendment, not a revision;
Petition’s estimated government expenditures are exaggerated and signatures gathering costs will be borne by proponents.

Several intervenors (DIK, MABINI, IBP, LABAN) contended the petition is improper, lacks the required signatures, and that R.A. No. 6735 is insufficient, thus COMELEC lacks jurisdiction.

Proceedings Before the Supreme Court
The Court issued a temporary restraining order (TRO) enjoining COMELEC from acting on Delfin’s petition and prohibiting the Pedrosas from conducting a signature drive.
Extensive briefing and hearings were held.
Multiple separate and dissenting opinions were submitted.
The Court took cognizance of issues regarding:

Whether R.A. No. 6735 (Initiative and Referendum Act) was intended and is adequate to cover initiative on amendments to the Constitution.
Whether COMELEC Resolution No. 2300’s provisions relating to initiative on constitutional amendments are valid.
Whether lifting term limits on elective officials constitutes a constitutional amendment or a revision.
Whether COMELEC has jurisdiction or may validly entertain Delfin’s petition, which lacks the required number of signatures.
Whether this Court may take cognizance of the special civil action for prohibition despite the pendency of the case before COMELEC.