Case Summary (G.R. No. L-18684)
Statement of Claims
The petitioners allege that Republic Act 3040 is constitutionally void for several reasons:
- It was passed by the House of Representatives without printed final copies of the bill being provided to its Members at least three calendar days prior to passage.
- It was enacted more than three years following the last census of the population, contrary to constitutional requirements.
- It apportions districts in a way that is not reflective of the population distribution across provinces.
The respondents, on the other hand, assert that they acted within their legal duties and presume that the statute is constitutional. They maintain that the petitioners lack the standing to bring this action and that the statutory presumption of compliance with legislative procedures must prevail.
Judicial Analysis of Personality
The Court finds that the petitioners possess the requisite personality to initiate this action. As representatives and voters from provinces allegedly impacted by the apportionment, they have a legal interest in ensuring their franchise is not diminished by the contested law. The jurisprudence cited, including precedent cases that uphold the standing of citizens to challenge redistricting statutes, supports the notion that those deprived of fair representation have a right to seek judicial remedy.
Legislative Procedure and Constitutional Requirement
The 1987 Constitution mandates that no bill shall be passed by either house unless the final printed copies are distributed to the members at least three calendar days prior to enactment, unless a certification of urgency is provided by the President. The petitioners presented evidence indicating that no printed copy was distributed three days in advance of the law’s passage, nor was there a presidential certification of urgent enactment. The respondents' argument that such legislative procedural discrepancies cannot invalidate a statute due to a presumption of compliance is countered by the premise that the three-day printing requirement is a fundamental aspect of legislative procedure imbued with constitutional significance.
Validity of Population Census
The Constitution further stipulates that Congress is obliged to apportion members based on the census conducted every three years. It has been presented that Republic Act 3040 was based on a preliminary population report submitted by the Director of the Census, which petitioners argue is insufficient since it is subject to revision. The respondents argue that the report should suffice for the legislative action. Relevant jurisprudence indicates that even preliminary census data can act as a basis for legislative apportionment, creating a judicially cognizable issue.
Apportionment of Legislative Members
The essential constitutional directive is that the distribution of members within the House of Representatives must reflect the inhabitants' numbers as closely as possible. The Court has noted various instances where the apportionment under Republic Act 3040 did not adhere to this criterion, resulting in significant disparities in representation across provinces. These inequalities are strikingly apparent, with districts receiving unequal representation despite varying population sizes, thus violating the equal protection clause inherent in the Constitution.
Judicial Review of Political Questions
Respondents posited that since Republic Act 3040 marginally improved the existing conditions of
...continue readingCase Syllabus (G.R. No. L-18684)
Statement of the Case
- Petitioners request the Court to prevent the implementation of Republic Act 3040, which apportions representative districts in the Philippines.
- They allege the Act is unconstitutional and void for three main reasons:
- It was passed without printed final copies being provided to House Members at least three calendar days prior to its passage.
- It was approved more than three years after the last population census.
- It apportioned districts without considering the population of the provinces.
- Respondents admit to some allegations but assert they were merely fulfilling their statutory duties, claiming the Act is constitutional.
- The National Treasurer argues that petitioners lack the standing to file the action, asserting that a certified copy of the law creates a presumption of its constitutionality and proper enactment.
Personality of the Petitioners
- Petitioners include four members of the House of Representatives from Negros Oriental, Misamis Oriental, and Bulacan, as well as the provincial governor of Negros Oriental.
- They allege that their provinces were discriminated against in the apportionment process due to insufficient representative districts compared to their populations.
- The Court finds that petitioners, as voters and representatives of the aggrieved provinces, have the legal standing to sue, citing precedent that citizens deprived of equitable representation may challenge apportionment statutes.
The Printed-Form, Three-Day Requirement
- The Constitution mandates that no bill shall be passed unless printed copies are furnished to Members at least three days prior, except in cases of presidential certification for immediate enact