Case Summary (G.R. No. 118303)
Origination Requirement under the 1987 Constitution
• Constitutional Mandate: Bills of local application must originate exclusively in the House of Representatives.
• Petitioners’ Argument: Passage of SB No. 1243 in the Senate shows the law did not originate exclusively in the House.
• Court’s Analysis: HB No. 8817 was filed on April 18, 1993, whereas SB No. 1243 was filed only on May 19, 1993. The House bill initiated the legislative process and was approved on Third Reading before Senate action. The Senate’s filing of a counterpart bill in anticipation does not violate the exclusivity rule, so long as it refrains from taking final action until it receives the House bill (Tolentino v. Secretary of Finance). No breach of Article VI, Section 24 occurred.
Presumption of Constitutionality
• General Rule: Every law enjoys a presumption of constitutionality, which can be overcome onl
Case Syllabus (G.R. No. 118303)
Factual Background
- Petition for Prohibition with prayer for Temporary Restraining Order and Preliminary Injunction filed by petitioners challenging Republic Act No. 7720.
- RA No. 7720: “An Act Converting the Municipality of Santiago, Isabela into an Independent Component City to be known as the City of Santiago,” signed May 5, 1994.
- House Bill No. 8817 filed April 18, 1993; principal author Rep. Antonio Abaya; referred May 5, 1993 to House Committees on Local Government and Appropriations.
- Public hearings conducted May 19, June 1, November 28, December 1, 1993; favorable House committee report with amendments dated December 9, 1993.
- HB No. 8817 passed Second Reading December 13, 1993 and Third Reading December 17, 1993; transmitted to the Senate January 28, 1994.
- Senate Bill No. 1243, counterpart to HB No. 8817, introduced May 19, 1993 by Sen. Vicente Sotto III; public hearings February 23, 1994.
- Senate Committee on Local Government issued Committee Report No. 378 on March 1, 1994 recommending approval without amendment; petitioning Senator Alvarez was a signatory.
- SB No. 1243 passed Second Reading March 3, 1994; Third Reading March 14, 1994.
- House approved Senate amendments March 22, 1994; enrolled bill submitted April 12, 1994 and signed by the President May 5, 1994.
- Plebiscite held July 13, 1994: overwhelming voter approval for city conversion.
Issues Presented
- Whether Internal Revenue Allotments (IRAs) must be included in computing a municipality’s average annual income for conversion into an independent component city.
- Whether Republic Act No. 7720 originated exclusively in the House of Representatives as required by Section 24, Article VI of the 1987 Constitution, notwithstanding the Senate’s passage of SB No. 1243.
Inclusion of IRAs in LGU Annual Income
- Petitioners’ computation:
• Total income (1991 & 1992, at 1991 constant prices)