Title
Supreme Court
Province of Sulu vs. Salvador C. Medialdea
Case
G.R. No. 242255
Decision Date
Sep 9, 2024
The Supreme Court partially granted the Province of Sulu's petition, declaring the inclusion in BARMM unconstitutional, upholding local autonomy and the right to suffrage.

Case Digest (G.R. No. 242255)
Expanded Legal Reasoning Model

Facts:

  • Background and Historical Context
    • The struggle of the Bangsamoro people for self-determination dates back to the early days of imperialism, with pivotal events including the 1968 Jabidah Massacre which escalated armed conflict.
    • The implementation of Martial Law in 1972 intensified rebellion, leading to peace agreements such as the 1976 Tripoli Agreement, which provided principles for Muslim autonomy.
    • Autonomous Region in Muslim Mindanao (ARMM) was created through Republic Act No. 6734 in 1989 and later strengthened by Republic Act No. 9054 in 2001.
  • Peace Negotiations and Legislative Measures
    • Formal peace talks with Moro groups including the Moro Islamic Liberation Front (MILF) took place from the late 1990s to early 2000s.
    • Several peace agreements were signed, culminating in the Framework Agreement on the Bangsamoro in 2012 and the Comprehensive Agreement on the Bangsamoro in 2014.
    • The Bangsamoro Organic Law (Republic Act No. 11054) was enacted in 2018, repealing previous organic acts and creating the Bangsamoro Autonomous Region in Muslim Mindanao (BARMM).
  • Legal Challenges Against the Bangsamoro Organic Law
    • Province of Sulu, Philippine Constitution Association (PHILCONSA), and other groups filed petitions challenging the constitutionality of RA 11054 and sought to enjoin the conduct of plebiscites.
    • Main contentions included:
      • The abolition of a constitutionally created ARMM through legislation is unconstitutional.
      • The parliamentary form of government established for BARMM lacks an elected executive.
      • Inclusion of the entire ARMM as a single geographical entity infringes on the right of suffrage of constituent provinces that voted against inclusion.
      • The law allegedly erases indigenous peoples' identity and favors the MILF in governance, violating equal protection.
  • Plebiscite Conduct and Results
    • The plebiscites for ratification of the Bangsamoro Organic Law were conducted on January 21 and February 6, 2019 in various areas.
    • Majority votes favored the law overall, but the Province of Sulu voted majority "no" to inclusion in BARMM.
    • Despite this, the Province of Sulu was included in BARMM as ARMM provinces voted as one geographical area.
  • Procedural History
    • The Supreme Court consolidated the petitions and issued resolutions directing comments, interventions, and memoranda.
    • Issues of justiciability, legal standing, and the ponente's motion for inhibition were raised and addressed.
    • Various parties including MILF, League of Bangsamoro Organizations, and others filed comments supporting the constitutionality of the law.

Issues:

  • Whether the ponente (Justice Leonen) should inhibit from the case due to prior involvement in peace negotiations.
  • Whether the petitions present actual cases or controversies and whether petitioners have legal standing.
  • Whether the Bangsamoro Organic Law violates the Constitution, specifically:
    • Whether BARMM is a constitutionally valid autonomous region replacing ARMM.
    • Whether Congress has the power to abolish ARMM and enact the Bangsamoro Organic Law.
    • Whether BARMM constitutes a separate state or remains within the Philippine state.
    • Whether the inclusion of the Province of Sulu despite its rejection in the plebiscite is constitutional.
    • Whether the law violates the rights and identity of indigenous peoples.
  • Whether the parliamentary form of government in BARMM complies with constitutional requirements.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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