Case Summary (G.R. No. 246328)
Applicable Law
The proceedings are based on the 1987 Philippine Constitution, specifically on the relevant provisions governing election schedules and the representation of legislative districts. Additionally, the case cites Republic Act No. 7166 and R.A. 11243.
Background of the Case
On March 11, 2019, President Duterte signed R.A. 11243 into law, creating the lone legislative district of General Santos City and stipulating that elections for representatives from this district would be held in the next national and local elections following the law's effectivity. The law took effect on April 4, 2019, just over a month before the planned elections.
COMELEC's Resolution
On April 11, 2019, COMELEC issued Resolution No. 10524, which suspended the upcoming elections for the representative of the First Legislative District of South Cotabato, including General Santos City. The resolution argued that the current electoral configurations were not compliant with the newly established boundaries and could not be modified in time for the elections due to operational and logistical constraints. Consequently, COMELEC scheduled the elections for the representative positions to be held "within six months from May 13, 2019," and declared any votes for the position in the scheduled elections as "stray."
Petitioners' Arguments
The petitioners challenged the validity of COMELEC's resolution, arguing that the election schedule contradicted R.A. 7166, which mandates that elections for members of the House of Representatives be held on the second Monday of May every three years. They contended that R.A. 11243 sought to initiate its provisions in the May 2022 elections and that conducting special elections so soon after the law's enactment was erroneous. Further, they expressed concern that if the votes were regarded as stray, it would leave the First District without representation until new elections were held.
Resolutions and Elections Held
Despite the ongoing petition, the general elections proceeded on May 13, 2019. Votes were cast for the position in question, with BaAas-Nograles receiving the majority. However, in accordance with COMELEC's directive, these votes were declared stray, and she was not proclaimed as the representative.
Subsequent Developments
BaAas-Nograles filed multiple requests to be recognized as the winning candidate and sought a Status Quo Ante Order to restore the right of the electorate to vote. COMELEC maintained its position that postponing the elections was justified due to the pre-existing logistical challenges.
Legal Findings
The Court ultimately found in favor of the petitioners, asserting that the provisions of the 1987 Constitution regarding election schedules are explicit, mandating elections for Congress on the second Monday of May unless specifically directe
...continue readingCase Syllabus (G.R. No. 246328)
Case Background
- This case involves a petition for review filed under Rule 64 of the Rules of Court contesting the Commission on Elections (COMELEC) Resolution No. 10524, issued on April 11, 2019.
- The resolution suspended the May 13, 2019, national and local elections for the Representative of the First Legislative District of South Cotabato, which includes General Santos City.
Factual Antecedents
- On March 11, 2019, Republic Act No. (R.A.) 11243 was signed into law by President Rodrigo Roa Duterte, reapportioning the First Legislative District of South Cotabato and creating a lone legislative district for General Santos City.
- The law mandated that the new district would come into effect in the next national and local elections following the law's enactment, which took effect on April 4, 2019.
- COMELEC was tasked with issuing the necessary rules to implement R.A. 11243.
COMELEC's Resolution
- In the assailed resolution, COMELEC indicated that the electoral data for the First Legislative District had already been configured in the automated election system, which was inconsistent with the requirements of R.A. 11243.
- Due to logistical constraints, including the filing of Certificates of Candidacy and ballot finalization, COMELEC decided to:
- Suspend the election for the representative of the First Legislative District on May 13, 2019.
- Consider any votes for this position as stray.
- Schedule the first regular election for the new representatives within six months from May 13, 2019.