G.R. No. 203974 - Umali vs. Commission on Elections

Background of the Conversion of Cabanatuan City into a Highly Urbanized City (HUC)

On July 11, 2011, the Sangguniang Panglungsod of Cabanatuan City passed Resolution No. 183-2011 requesting the President to declare the conversion of Cabanatuan City from a component city of Nueva Ecija province into a highly urbanized city (HUC).
The President issued Presidential Proclamation No. 418 (2012) proclaiming Cabanatuan City as an HUC, subject to ratification via plebiscite by qualified voters, per Section 453 of the Local Government Code (LGC) of 1991.

The Commission on Elections (COMELEC) issued Minute Resolution No. 12-0797 on September 11, 2012, resolving that only registered residents of Cabanatuan City should participate in the plebiscite. This relied on LGC Section 453 and past precedents involving Puerto Princesa, Tacloban, and Lapu-Lapu Cities.
Governor Aurelio M. Umali of Nueva Ecija filed a Verified Motion for Reconsideration arguing that the conversion directly affects the province and that Section 453 should be read with Section 10, Article X of the Constitution. He contended that qualified voters of all affected LGUs, including the province, should vote given the material impact on the province’s political and economic rights.

Mayor Julius Cesar V. Vergara opposed the motion, asserting that Section 10, Article X does not apply to conversions and that the specific LGC provision (Section 453) limits voting to city residents. He cited prior conversions with similar limited voting.
COMELEC, after a hearing on October 4, 2012, denied Governor Umali’s motion on October 16, 2012 via Minute Resolution No. 12-0925, affirming that only registered voters of Cabanatuan City should participate. Two commissioners dissented.

Dr. Rodolfo B. Punzalan filed a Petition for Declaratory Relief seeking to include all Nueva Ecija voters in the plebiscite and halt COMELEC’s implementation. The RTC issued a Temporary Restraining Order (TRO) on October 19, 2012.
COMELEC suspended plebiscite preparations on November 6, 2012 and rescheduled the plebiscite to avoid conflict with May 13, 2013 elections.
Petitioner J.V. Bautista sought mandamus before the Supreme Court to compel COMELEC to schedule the plebiscite earlier, arguing the expiration of the TRO and the mandatory duty to conduct the plebiscite within 120 days.
COMELEC defended the postponement citing ongoing legal disputes and local violence during the plebiscite period.
COMELEC finally scheduled the plebiscite for January 25, 2014, but the Supreme Court issued a TRO to suspend the plebiscite on January 15, 2014.
The petitions for certiorari and mandamus were consolidated on March 18, 2014.

Whether the qualified registered voters of the entire province of Nueva Ecija or only the registered voters of Cabanatuan City should participate in the plebiscite to ratify the conversion of Cabanatuan City from a component city to a highly urbanized city.

Whether Section 453 of the Local Government Code, which permits only city voters to vote in the plebiscite, conflicts with Section 10, Article X of the Constitution requiring the participation of voters of political units directly affected.