Case Summary (G.R. No. L-11107)
Background and Issue
The Province of Guimaras, having been reclassified from a fifth to a fourth class province due to the addition of two municipalities (San Lorenzo and Sibunag), was subject to redistricting of its Sangguniang Panlalawigan seats. Pursuant to Resolution No. 68 passed by the Guimaras Sangguniang Panlalawigan on March 25, 1996, and following consultative meetings conducted by the Provincial Election Supervisor, the division of Guimaras into two provincial districts was proposed. The COMELEC issued Resolution No. 2950, dividing the province into two districts and allocating eight elective Sangguniang Panlalawigan seats accordingly. Petitioners challenged the resolution on grounds of grave abuse of discretion.
Petitioners' Contentions
- The districts do not constitute compact, contiguous, and adjacent territorial areas.
- The consultative meetings did not accurately represent the voters’ true sentiment.
- The apportionment into two districts is inequitable in terms of representation.
- There is significant disparity in the ratio of voters per Sangguniang Panlalawigan member across districts.
- Petitioners proposed an alternative redistricting plan that offers more equal voter-to-member ratios.
Legal Framework on Apportionment
Under Republic Act No. 6636, the number of elective Sangguniang Panlalawigan members per province depends on its classification: fourth class provinces, such as Guimaras following its reclassification, are entitled to eight members. Republic Act No. 7166 mandates that provinces with only one legislative district must be divided into two Sangguniang Panlalawigan districts in a manner:
- As nearly as practicable according to the number of inhabitants,
- Each district must comprise compact, contiguous, and adjacent territory,
- Number of seats to be equitably apportioned between the districts.
COMELEC Resolution No. 2131 supplements this by requiring the use of the latest census population data (1990 Census, updated to 1995 in this case), holding consultations with concerned officials and sectors, and maintaining municipal integrity within a single district.
Basis for Apportionment: Inhabitants, Not Registered Voters
The COMELEC based the division on the population figures from the 1995 Census of Population, as certified by the National Statistics Office, rather than on the number of registered voters or taxpayers as claimed by petitioners. The Court emphasized that R.A. 7166 and COMELEC guidelines prescribe population-based apportionment, rendering petitioners' reliance on voter registration data untenable. The alleged disparity in representation ratios is therefore not valid under the law.
Adequacy and Representation in Consultative Meetings
The Provincial Election Supervisor validly conducted two consultative meetings with proper notice to and representation by all relevant stakeholders, including elected officials, barangay captains, and political party representatives. Attendance sheets and documentary exhibits attached by the COMELEC confirm sufficient and appropriate representation, negating petitioners’ claim that the meetings failed to reflect the electorate’s true sentiment.
Compactness and Contiguity of Districts
The Court held that the two districts as constituted are composed of contiguous and adjacent municipalities. Buenavista and San Lorenzo, grouped in the first district, share common borders and are geographically connected,
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Case Background and Nature of Petition
- Petitioners, taxpayers and residents of the Province of Guimaras, filed a petition for certiorari to annul and set aside Resolution No. 2950.
- Resolution No. 2950 was promulgated on November 3, 1997, by the Commission on Elections (COMELEC).
- The resolution amended prior COMELEC resolutions concerning the districting and adjustment of Sangguniang Panlalawigan and Panglungsod seats for the May 11, 1998 elections.
- Petitioners alleged grave abuse of discretion in the division of Guimaras Province into two provincial districts and the apportionment of eight elective Sangguniang Panlalawigan seats.
- The case centers on the legality and propriety of COMELEC’s districting scheme in light of relevant laws and constitutional mandates.
Factual Background on Districting of Guimaras Province
- The Province of Guimaras had two new municipalities added: San Lorenzo and Sibunag.
- The Sangguniang Panlalawigan of Guimaras, upon these developments, resolved to subdivide the province into two provincial districts via Resolution No. 68 dated March 25, 1996.
- The Provincial Election Supervisor conducted two consultative meetings on August 21, 1996, and October 2, 1996, with comprehensive participation of elected officials, barangay leaders, political party representatives, and civil society.
- Consensus through secret balloting favored the division:
- First District: Municipalities of Jordan, Buenavista, and San Diego with 3 Sangguniang Panlalawigan Members.
- Second District: Municipalities of Jordan, Nueva Valencia and Sibunag with 3 Sangguniang Panlalawigan Members.
- A memorandum recommending the division was issued following the consultative meetings.
Reclassification and Issuance of COMELEC Resolution No. 2950
- On April 30, 1997, the Bureau of Local Government Finance, Department of Finance, reclassified Guimaras from a fifth-class to a fourth-class province under Memorandum Circular No. 97-1.
- Pursuant to this reclassification and the mandates of electoral laws, COMELEC issued Resolution No. 2950 allocating eight (8) Sangguniang Panlalawigan seats to Guimaras.
- The province was divided into two districts as follows:
- First District (3 seats): Buenavista (37,681 voters) and San Lorenzo (18,537 voters) totaling 56,218 inhabitants.
- Second District (5 seats): Jordan (25,321), Nueva Valencia (27,158), Sibunag (17,773) totaling 70,252 inhabi