G.R. No. 125416 - Subic Bay Metropolitan Authority vs. Commission on Elections

On March 13, 1992, Congress enacted Republic Act No. 7227 (Bases Conversion and Development Act of 1992), creating the Subic Special Economic and Freeport Zone (SSEZ) and the Subic Bay Metropolitan Authority (SBMA). Section 12 required concurrence by the Sangguniang Panlungsod of Olongapo and the Sangguniang Bayan of Subic, Morong, and Hermosa.
SBMA was capitalized at ₱20 billion, fully subscribed and paid by the Republic, and vested with all lands defined in Section 12. On November 24, 1992, the U.S. Navy turned over the Subic Naval Base and its extensions to the Philippine government.

In April 1993, the Sangguniang Bayan of Morong passed Pambayang Kapasyahan Blg. 10, Serye 1993, “concurrence” to join the SSEZ, and submitted it to the President on September 5, 1993.
On May 24, 1993, Enrique T. Garcia, Catalino A. Calimbas and others filed with the Sangguniang Bayan of Morong a petition to annul P.K. Blg. 10 and replace it with a conditional concurrence containing ten specific demands (items A–J). The Sanggunian responded by passing Pambayang Kapasyahan Blg. 18, Serye 1993, requesting certain amendments to RA 7227.

Comelec Resolution No. 93-1623 (July 6, 1993) denied the local initiative for lack of ordinance form; Resolution No. 93-1676 (July 13, 1993) directed signature authentication.
On August 15, 1993, the petitioners filed a certiorari and mandamus petition (G.R. No. 111230) challenging those resolutions. This Court, in Enrique T. Garcia et al. v. Comelec (237 SCRA 279, 1994), held that resolutions may be subject to initiative and referendum.

On February 1, 1995, Proclamation No. 532 defined the metes and bounds of the SSEZ, including Grande Island and former Morong naval lands.
Comelec Resolution No. 2845 (June 18, 1996) adopted a calendar for a local referendum on annulling P.K. Blg. 10; Resolution No. 2848 (June 27, 1996) set the rules and guidelines for that referendum.
On July 10, 1996, SBMA filed the present petition for certiorari and prohibition against Resolution No. 2848, alleging grave abuse of discretion and lack of jurisdiction in permitting an initiative to amend a national law.
On July 23, 1996, after oral argument, Comelec en banc stayed the July 27 referendum. The Court deemed the TRO application moot and submitted the case for resolution.

Does the earlier final judgment in G.R. No. 111230 bar the present petition?
Did the Comelec commit grave abuse of discretion in promulgating and implementing Resolution No. 2848 by treating an initiative as a referendum and failing to review the sufficiency and form of the proposal?
Is the subject of the proposed initiative—annulment and conditional replacement of Pambayang Kapasyahan Blg. 10—within the legislative power of the Sangguniang Bayan of Morong, or does it seek to amend a national law ultra vires?