Case Summary (G.R. No. 215370)
Key Dates and Applicable Law
– December 22, 1979: Enactment of Batas Pambansa Blg. 51.
– January 30, 1980: Scheduled local elections.
– January 28, 1980: Supreme Court decision.
Governing law is the 1973 Constitution (Arts. II, XI) and Batas Blg. 51, Sec. 3 (classification of cities by income), plus RA 5519, Sec. 96.
Material Facts
Batas Blg. 51 classifies cities with annual income ≥ ₱40 million as “highly urbanized,” whose registered voters cannot vote for provincial officials, while component cities may if their charters permit. Cebu City (₱51.6 million) is thus “highly urbanized” despite its charter allowing provincial voting. Mandaue City, with income below the threshold, is a component city whose charter expressly bars its voters from provincial elections.
Issues Presented
- Whether classifying cities by income and barring “highly urbanized” city voters from provincial elections violates equal protection or suffrage rights.
- Whether RA 5519’s charter provision is invalid for lack of plebiscitary ratification.
- Whether Batas Blg. 51 or RA 5519 was enacted for impermissible political motives.
Petitioners’ Contentions
– Income-based classification lacks substantial distinctions germane to suffrage regulation and denies equal protection.
– Mandaue City’s charter is void for not being ratified in a plebiscite, in violation of constitutional requirements.
– The measures were motivated by gerrymandering to disenfranchise opposition votes in Cebu Province.
Constitutional and Precedent Analysis
Under the 1973 Constitution the State guarantees local autonomy (Arts. II, XI). Art. XI, Sec. 4(1) places highly urbanized cities outside provincial supervision; independence from provincial authority logically forecloses participation in provincial elections. In Teves v. Comelec (90 Phil. 370), the Court held that a city separated from its province may not vote for provincial officials absent express charter provision. Income is a substantial distinction: it reflects a city’s capacity for self-government and justifies autonomy.
Equal Protection and Suffrage Considerations
Allowing some component-city voters but not others rests on legislative discretion over local units and charters; silence in a charter implies exclusion. No undue burden akin to invalidated poll taxes has been imposed, and the Constitution confers no inherent right for city voters to vote for provincial officials. Disparate treatment among cities does not deny equal protection so long as categories rest on rational, germane distinctions.
Plebiscite Requirement and Prospective Effect
The 1
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Procedural History
- Petitioners filed an original action for prohibition and mandamus with prayer for a writ of preliminary injunction before the Supreme Court En Banc on January 28, 1980.
- They challenged the constitutionality of Section 3 of Batas Pambansa Blg. 51 (Local Elections Act) and Section 96, Article XVIII of Republic Act No. 5519 (Mandaue City Charter).
- The prayer for relief included:
• Temporary restraining order preventing provincial elections in provinces where the 18 cities listed by COMELEC (including Cebu City and Mandaue City) are located.
• Prohibition of fund release by the National Treasurer and audit clearance by the Commission on Audit in connection with those elections.
• Permanent injunction declaring the challenged provisions void or, alternatively, directing COMELEC to prepare ballots allowing city voters to vote for provincial officials.
Statutory Provisions Involved
- Section 3, Batas Pambansa Blg. 51:
• Classification of chartered cities into “highly urbanized” (annual income ≥ ₱40,000,000 or special status for Baguio) and “component” cities.
• Voting rights in provincial elections depend on city classification and charter provisions. - Article XI, Section 4(1), 1973 Constitution:
• Highly urbanized cities are outside provincial supervision. - Republic Act No. 5519 (Charter of Mandaue City), Section 96:
• Express prohibition on Mandaue City voters participating in provincial elections, except as candidates.
Commission on Elections Resolution
- COMELEC Resolution No. 1421 implemented BP Blg. 51’s city classification for purposes of provincial elections.
- Listed twenty cities whose qualified voters “shall not participate nor vote in the election of the officials of the province in which the highly urbanized city is geographically located,” including Cebu City and Mandaue City as determined by income and charter provisions.
Facts
- Cebu City’s 1979 annual income of ₱51,603,147.64 qualified it as a highly urbanized city; its voters were thus barred from provincial elections despite its charter allowing such participation.
- Mandaue City’s income was