Case Digest (G.R. No. L-34150) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. L-34150 decided on November 4, 1971, Arturo M. Tolentino filed a petition against the Commission on Elections and the Chief Accountant, Auditor, and Disbursing Officer of the 1971 Constitutional Convention, with Raul S. Manglapus, Jesus G. Barrera, Pablo S. Trillana III, Victor de la Serna, Marcelo B. Fernan, Jose Y. Feria, Leonardo Sigüion Reyna, Victor F. Ortega, and Juan V. Borra as intervenors. The petition sought to annul Organic Resolution No. 1 of the Convention, which proposed an amendment to Section 1, Article V of the 1935 Constitution reducing the voting age from twenty-one to eighteen years “without prejudice to other amendments”, and to submit that single provision to a plebiscite coincident with the November 8, 1971 election of senators and local officials, using part of the Convention’s funds. The Court’s earlier decision declared the resolution null and void for violating the amendatory procedure in Section 1, Article XV of the Constitution by attempt Case Digest (G.R. No. L-34150) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Case
- Arturo M. Tolentino (Petitioner) challenged CC Organic Resolution No. 1 of the 1971 Constitutional Convention, which proposed lowering the voting age from 21 to 18 and submitting that change in a plebiscite coinciding with the November 8, 1971 elections, while “without prejudice” to other future amendments.
- The Supreme Court initially held Organic Resolution No. 1 null and void for failing to conform to Article XV, Section 1 of the Constitution, which prescribes the manner of proposing and submitting amendments.
- Motions for Reconsideration
- Respondent Commission on Elections and Convention officers, joined by intervenors, moved for reconsideration, arguing:
- The Convention, like Congress as a constituent assembly, may submit amendments singly or collectively.
- The singular phrase “at an election” may include multiple plebiscites.
- The Court should not review the Convention’s procedural wisdom.
- The age-reduction amendment is simple and needs no broader constitutional context.
- Petitioner filed timely answers opposing reconsideration.
- Constitutional and Historical Context
- Article XV, Section 1 of the 1935 Constitution (as amended) allows amendments by joint resolution of Congress or by a convention, to be ratified “by a majority of the votes cast at an election at which the amendments are submitted to the people.”
- Historical practice (1939–1940) shows proposed amendments approved by the National Assembly were submitted only after each constituent session adjourned, and then all amendments voted as a complete set.
Issues:
- May the Constitutional Convention submit a single, partial amendment (lowering voting age) in advance plebiscite before approving all other proposed amendments?
- Does the phrase “at an election” permit multiple plebiscites for different amendments?
- Is the choice of submitting amendments in separate plebiscites a non-justiciable matter of Convention wisdom?
- Does a simple age-reduction amendment require no constitutional “frame of reference” to be submitted validly?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)