Title
League of Cities of the Philippines vs. Commission on Elections
Case
G.R. No. 176951
Decision Date
Feb 15, 2011
Petitioners challenged 16 laws converting municipalities into cities, alleging violations of constitutional criteria and equal protection. The Court upheld the laws, ruling Congress validly exempted municipalities with pending cityhood bills from higher income requirements.

Case Summary (G.R. No. 176951)

Procedural Background

– Petitioners sought prohibition and declaratory relief to enjoin plebiscites under the cityhood laws, arguing their unconstitutionality.
– En Banc (6–5) granted relief (Nov. 18, 2008); first reconsideration denied (7–5, Mar. 31, 2009); second considered prohibited but voted on and denied (6–6 deadlock, Apr. 28, 2009).
– En Banc (6–4) reversed stance and upheld statutes (Dec. 21, 2009).
– En Banc (7–6) later reinstated the November 2008 decision (Aug. 24, 2010).
– Respondent municipalities moved for reconsideration of the Aug. 24, 2010 resolution, prompting the present ruling.

Issue 1: Compliance with Article X, Section 10

Article X, Section 10 mandates that creation or conversion of local government units conform to criteria in the Local Government Code and be approved by plebiscite. Congress amended Section 450 of the Code via RA 9009 (effective June 30, 2001) raising the income requirement for component cityhood from ₱20 million to ₱100 million (locally generated, constant-2000 prices). The sixteen cityhood statutes each contain an explicit exemption clause applying the prior ₱20 million threshold to the subject municipalities. Petitioners argued the exemptions subvert the uniform criteria of the Code; petitioners also invoked legislative intent behind RA 9009’s higher requirement.

Legislative History and Exemption Clauses

– Sponsor’s speeches and interpellations in the Senate reveal Congress intended two goals: (a) to deter a “mad rush” of cityhood bids by raising the income bar; and (b) to exempt pending bills from that new threshold so as not to penalize municipalities whose cityhood measures were already under consideration.
– Senate President and sponsor agreed that, absent a retroactivity clause, the amended income requirement would not apply to pending cityhood bills.
– Congress reaffirmed this intent in the succeeding sessions, culminating in the enactment of each cityhood law bearing its own exemption clause.
– These statutes thus operate as legislative amendments to the Code’s applicability for those municipalities.

Court’s Analysis on Article X, Section 10

– Exemption clauses embody Congress’s express will to apply the old income requirement to the sixteen municipalities; such intent is evident from legislative debates and enactment history.
– Uniformity of the Code’s criteria is preserved because the local government units remain subject to Section 450—only the income threshold differs by explicit legislative carve-out.
– The Court defers to Congress’s plenary lawmaking power, recognizing its authority to amend the Code, including by narrow exemptions, absent clear constitutional prohibition.

Issue 2: Equal Protection Clause

The Equal Protection Clause permits classification if it: (1) rests on substantial distinctions; (2) is germane to the law’s purpose; (3) is not limited to existing conditions only; and (4) applies equally within the class.

Court’s Analysis on Equal Protection

– The classification (municipalities with pending cityhood bills in the 11th Congress) rests on a material distinction tied to Congress’s policy judgment that those localities had earned the right to conversion under the prior Code standard.



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