Case Summary (G.R. No. L-32436)
Applicable Law
The case revolves around the interpretation and constitutionality of certain sections of Republic Act No. 6132, specifically Sections 4 and 8(a), which govern the participation of government officials in the Constitutional Convention as delegates.
Legislative History
On March 16, 1967, Congress passed Resolution No. 2, which called for a Constitutional Convention. This Resolution stipulated that the office of delegate was honorary and compatible with other public offices. On June 17, 1969, Congress amended this Resolution through Resolution No. 4, which led to the enactment of Republic Act No. 6132 on August 24, 1970, as the implementing legislation.
Petitioners' Claims
The petitioners argue that Sections 4 and 8(a) of Republic Act No. 6132 violate the provisions of Resolution No. 2, particularly alleging inconsistency and asserting that these provisions effectively establish class legislation by disqualifying public officials from running for delegate positions without resigning from their posts.
Court's Reasoning on Legislative Intent
The Court ruled that Section 3 of Resolution No. 2, while declaring the office of delegate to be honorary and compatible with other public offices, does not preclude Congress from imposing certain restrictions on candidacy for public office, especially when these restrictions do not violate constitutional provisions.
The Court found that there was no inconsistency between the declaration in Resolution No. 2 and Republic Act No. 6132, as the provisions of the latter align with Section 2, Article XII of the Constitution, prohibiting civil service officials from engaging in partisan political activities, including campaigning for elections.
The Court acknowledged that allowing government officials to run for delegate positions without resigning from their posts could undermine the integrity of the civil service and disrupt public service, thus validating the provisions in question as serving public interest.
Public Interest and Legislative Power
The Court emphasized that the legislative intent behind Sections 4 and 8(a) is to protect the interest of the government and the public by ensuring that those in public service who choose to engage in political candidacy must relinquish their official duties to prevent conflicts of interest and maintain a non-partisan civil service.
Dissenting Opinions
Dissenting opinions, particularly from Justices Barredo and Zaldivar, argue that the provisions of Republic Act No. 6132 do not align with the original
...continue readingCase Syllabus (G.R. No. L-32436)
Case Overview
- This case involves petitions for declaratory relief concerning the validity and constitutionality of specific sections of Republic Act No. 6132.
- The petitions were filed by government officials and employees challenging the validity of Section 4 and Section 8(a), paragraph 2 of the Act.
- The case was argued in the Supreme Court, with participation from amici curiae, including notable senators.
Legislative Background
- On March 16, 1967, the Congress, meeting as a constituent assembly, passed Resolution No. 2, calling for a Constitutional Convention.
- Resolution No. 2 established that the office of Delegate is honorary and compatible with other public offices, allowing for certain compensations.
- On June 17, 1969, Congress passed Resolution No. 4, which amended Resolution No. 2 and mandated that implementing legislation should not contradict its provisions.
Republic Act No. 6132
- Approved on August 24, 1970, Republic Act No. 6132 serves as the implementing legislation for the Constitutional Convention.
- Key Provisions:
- Section 4 states that any public officeholder, including members of the armed forces, is considered resigned upon filing a certificate of candidacy.
- Section 8(a) prohibits certain government officials from intervening in the nominations or campaigns of candidates.
Petitioners' Arguments
- Petitioners argue that:
- Sections 4 and 8(a) are inconsistent with Resolution No. 2 and violate