Title
Sula vs. Commission on Elections
Case
G.R. No. 244587
Decision Date
Jan 10, 2023
Plebiscite on Cotabato City's inclusion in Bangsamoro Autonomous Region upheld; SC ruled no irregularities, timely conduct, and true will reflected.
A

Case Digest (G.R. No. 48384)

Facts:

  • Organic Law for the Bangsamoro Autonomous Region in Muslim Mindanao (Republic Act No. 11054)
    • Enacted on July 21, 2018 to:
      • Determine the territory of the new autonomous region.
      • Secure the identity of the Bangsamoro people and indigenous cultural communities and identify those who wish to be included.
    • Took effect 15 days after complete publication—Official Gazette on August 6, 2018; two national dailies on July 31, 2018; local ARMM newspaper on August 25, 2018—thus effective on September 10, 2018.
  • Commission on Elections’ preparation and conduct of plebiscites
    • On December 13, 2018, COMELEC issued Resolution No. 10464 setting the January 21, 2019 plebiscite for ARMM, Isabela City, Basilan, and Cotabato City; and a second phase on February 2, 2019 for other areas.
    • The official Cotabato City ballot asked:
      • “PAYAG BA KAYO NA ISAMA ANG LUNGSOD COTABATO SA REHIYONG AWTONOMO NG BANGSAMORO?”
  • Plebiscite results and proclamation
    • January 21, 2019 plebiscite in Cotabato City yielded 38,682 “YES” and 24,994 “NO” votes out of 61,676 votes cast, but certificate showed only 39,027 actual voters.
    • COMELEC en banc ordered a retabulation, reconciled discrepancies, and on January 25, 2019 proclaimed ratification of RA 11054 and inclusion of Cotabato City in the Bangsamoro Autonomous Region.
  • Petition and intervenor proceedings
    • On March 1, 2019, Sula, Asi, and Malig filed a Rule 65 petition (certiorari, prohibition, mandamus, injunctive relief) challenging:
      • Conduct and timing of the January 21, 2019 plebiscite.
      • Ballot question framing.
      • Alleged scheduling beyond the 150-day period.
      • Alleged massive irregularities and discrepancy in vote tallies.
    • On December 5, 2019, Mayor Guiani-Sayadi filed a petition-in-intervention asserting direct public interest and taxpayer standing.
    • The case proceeded through motions to suspend comment periods, filings of comments, replies, and multiple urgent motions to resolve pending injunctive relief.

Issues:

  • Whether Mayor Guiani-Sayadi’s petition-in-intervention should be granted.
  • Whether COMELEC committed grave abuse of discretion in ratifying RA 11054 and including Cotabato City in BARMM via the January 21 and February 2, 2019 plebiscites.
  • Whether a Temporary Restraining Order or Writ of Preliminary Injunction should issue to enjoin COMELEC from implementing RA 11054 with respect to Cotabato City.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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