Case Summary (G.R. No. 188078)
Applicable Law and Jurisdiction
The decision is governed by the 1987 Constitution, specifically Section 5(3) Article VI, which stipulates that cities must have a population of at least 250,000 to be entitled to representation in Congress. The act of creating legislative districts falls under the jurisdiction of the judiciary, which has the authority to review laws for their constitutionality and adherence to constitutional mandates.
Judicial Review and Justiciability
The COMELEC contended that the population indicators used by Congress to enact RA 9591 were non-justiciable, a claim that the Court rejected. The Court emphasized its judicial review power extends to questions on apportionment laws, asserting that it must examine the validity of the population data that Congress relied upon. Without such oversight, the constitutional limitations on legislative representation risk becoming ineffectual.
Reliability of Population Indicators
The Court found the population indicators that Congress utilized were neither reliable nor authoritative according to Executive Order No. 135 (EO 135). Various certifications presented, including those from the National Statistics Office (NSO) and local entities, failed to meet the official requirements mandated by EO 135, which demands that population estimates must be conducted by authorized bodies with scientific rigor.
Demographic Projections
The specific population projection cited by the NSO Director fell short of the constitutional threshold of 250,000 constituents. The Court invalidated the figures provided, noting that projections should be based on demographic estimates certified by the NSCB and conducted at specified times, further underscoring the pitfalls of using non-authoritative sources.
Legislative District Compliance
The Court determined that not only did Malolos City fail to meet the population requirement, but the creation of its legislative district under RA 9591 also isolated the municipality of Bulacan from contiguous representation. This fragmentation both violates and undermines the constitutional demand for legislative districts to be contiguous and compact.
Conclusion on Representation
Ultimately, the Court ruled that Malolos City is entitled to representation in Congress only if it surp
...continue readingCase Syllabus (G.R. No. 188078)
Case Background
- The case revolves around the motion for reconsideration filed by the Commission on Elections (COMELEC) regarding the Supreme Court's decision dated January 25, 2010.
- The primary contention is the reliability of the population indicators used by Congress in enacting Republic Act No. 9591 (RA 9591), which pertains to the legislative district creation for Malolos City.
Legal Issues Presented
- COMELEC argues that the reliance on the Certification of Alberto N. Miranda of the National Statistics Office (NSO) is non-justiciable.
- The Court must determine whether the population indicators used by Congress comply with the constitutional requirement for legislative representation as per Section 5(3), Article VI of the 1987 Constitution.
Justiciability of Population Indicators
- The Court asserts the judicial review power over laws creating legislative districts is fundamental and must include subsidiary questions regarding their constitutionality.
- The ruling emphasizes that the reliability of population indicators, including those from Miranda, is a matter for judicial scrutiny, rejecting the idea that such issues are purely political and thus non-justiciable.
Examination of Population Indicators
- The Certification by Miranda, projecting Malo