Title
League of Cities of the Philippines vs. Commission on Elections
Case
G.R. No. 176951
Decision Date
Jun 28, 2011
The Supreme Court upheld the constitutionality of 16 Cityhood Laws, ruling they were validly enacted, did not violate the Constitution, and respected legislative prerogatives, despite multiple reversals.
cityhood laws
local government code
constitutionality
A

Case Summary (G.R. No. 176951)

Characterization of the April 29, 2011 filing as a prohibited second motion for reconsideration

The Court found that the April 29, 2011 Motion for Reconsideration was essentially a second motion for reconsideration because it reasserted issues identical to those already raised in the Ad Cautelam Motion for Reconsideration dated March 8, 2011. The resolution demonstrates the sameness of issues between the two motions, showing that the subsequent motion did not present materially new grounds that would distinguish it from the prior motion.

Governing rule forbidding second motions for reconsideration and the requisite exception

Section 2 of Rule 51 of the Rules of Court provides unqualifiedly that a second motion for reconsideration of a judgment or final resolution by the same party shall not be entertained. The Court reiterated its settled rule that only extraordinarily persuasive reasons and express leave first obtained will permit a second motion for reconsideration. The Supreme Court’s Internal Rules (Section 3, Rule 15) further affirms that the Court shall not entertain a second motion for reconsideration except in the higher interest of justice, and such exception requires an En Banc vote of at least two-thirds of actual membership; a second motion for reconsideration may be entertained only before the ruling sought to be reconsidered becomes final by operation of law or by the Court’s declaration.

Finality of the April 12, 2011 Resolution and consequence for the Motion for Reconsideration

The Court noted that the April 12, 2011 Resolution had declared the Ad Cautelam Motion for Reconsideration denied with finality. Because the ruling sought to be reconsidered had already been declared final by the Court, the procedural prerequisites for entertaining a second motion for reconsideration were absent. Consequently, the Court denied the Motion for Leave to File Motion for Reconsideration and the attached Motion for Reconsideration.

Distinction from earlier allowance of a second motion and application to the present request

Petitioners argued that the Court had earlier entertained and granted the respondents’ second motion for reconsideration in a different phase of the litigation. The Court distinguished the earlier instance—where the Court en banc had expressly allowed the respondents’ second motion for reconsideration (resolution of June 2, 2009)—from the present case. No similar en banc declaration or grant of leave existed for petitioners’ filing; thus the present filing remained a prohibited second motion for reconsideration.

Disposition: denial of leave and grant of entry of judgment

Because the petitioners’ motion was a prohibited second motion for reconsideration and the issues raised were repetitive, the Court denied the Motion for Leave to File Motion for Reconsideration and the attached Motion for Reconsideration. The Court granted respondents’ Motion for Entry of Judgment and directed the Clerk of Court to issue the Entry of Judgment forthwith. The Court ordered that no further pleadings or submissions by any party would be entertained.

Dissent (Justice Carpio): overview and principal conclusion

Justice Carpio dissented from the majority’s resolution, maintaining that the sixteen Cityhood Laws are unconstitutional. His dissent focuses on substantive constitutional arguments under the 1987 Constitution: violation of Article X, Section 10 (creation of local government units must follow criteria established in the Local Government Code), violation of the Equal Protection Clause, failure to comply with the P100 million income requirement under the amended Local Government Code (RA 9009), and violation of Article X, Section 6 (just share in national taxes). He concluded that the Cityhood Laws must be struck down and would have granted the League of Cities’ motion for reconsideration.

Carpio dissent: Section 10, Article X and the Local Government Code

Justice Carpio emphasized the constitutional command that creation of local government units “shall be in accordance with the criteria established in the local government code,” and he reasoned that the Cityhood Laws are laws separate and distinct from the Local Government Code and therefore may not legitimately create exceptions to the statutory criteria. He concluded the Cityhood Laws did not amend the Local Government Code and thus cannot lawfully circumvent the uniform criteria required by the Constitution.

Carpio dissent: equal protection, P100 million requirement, and Section 6, Article X (IRA allocation)

Justice Carpio argued that using the mere pendency of a cityhood bill in the 11th Congress as the classification criterion is not rationally related to the legislative purpose of ensuring fiscal viability. He held that RA 9009’s increased income requirement of P100 million (as an amendment of Section 450 of the LGC) is the prevailing statutory standard and must be strictly complied with; reliance on the old P20 million threshold is compliance with a repealed provision and unconstitutional. He also maintained that the Cityhood Laws undermine fair distribution of the Internal Revenue Allotment (Section 6, Article X) because exempting certain municipalities skews IRA allocation and creates economic inequities with existing cities.

Carpio dissent: on the Legislature’s policy choices and practical consequences

While rejecting the majority’s characterization that the P100 million requirement was arbitrary, Justice Carpio stated that legislative judgments on thresholds are political and the Court should not invalidate them absent constitutional violation. He also noted existing cities need not comply retroactively with RA 9009 but that exemptions for the sixteen municipalities nevertheless create unfair classification and economic consequences that justify invalidation of the Cityhood Laws.

Dissent (Justice Sereno): stability of law, institutional concerns, and procedural critique

Justice Sereno’s separate dissent addressed the broader institutional and rule-of-law implications of

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