Title
Supreme Court
Province of Sulu vs. Salvador C. Medialdea
Case
G.R. No. 242255
Decision Date
Sep 9, 2024
The Supreme Court partially granted the Province of Sulu's petition, declaring the inclusion in BARMM unconstitutional, upholding local autonomy and the right to suffrage.

Case Summary (G.R. No. 242255)

Overview of the Proceedings

The Supreme Court dealt with consolidated petitions filed against Republic Act No. 11054, the Bangsamoro Organic Law (BOL). The petitioners sought a declaration of the law's unconstitutionality and requested the Court to enjoin the plebiscite conducted for its ratification. The Province of Sulu argued that the BOL unlawfully abolished the Autonomous Region in Muslim Mindanao (ARMM) and violated constitutional provisions regarding local governance and self-determination.

Historical Context of the Bangsamoro Conflict

The roots of the conflict pertaining to the Bangsamoro people's autonomy can be traced back to systemic injustices against Muslim minorities in the Philippines. Key historical events, such as the Jabidah Massacre and subsequent declarations of Martial Law, fueled unrest and the demand for self-governance, ultimately leading to various agreements and the eventual establishment of autonomous regions recognized under the 1987 Constitution.

Legal Framework and Conventions

According to Article X, Section 18 of the 1987 Constitution, the basis for creating autonomous regions lies in the enactment of organic acts by Congress, which must define their governance structures. The BOL aimed to create the Bangsamoro Autonomous Region in Muslim Mindanao (BARMM) with its political framework while addressing the historical aspirations of the Bangsamoro people for autonomy.

Core Legal Issues

The Court addressed whether the BOL's enactment violated constitutional provisions and whether the plebiscite conducted was valid. Central to the petitioners' argument was the assertion that the inclusion of the Province of Sulu in BARMM, despite its rejection in the plebiscite, constituted a breach of constitutional rights, particularly the right to suffrage and local autonomy.

Constitutional Analysis

The Court clarified that the Constitution permits Congress to amend, replace, or repeal existing organic acts of regions as long as such amendments respect the constitutional framework and are validated by a plebiscite. The BOL represents a continuation of the legislative evolution concerning Muslim autonomy and does not contravene constitutional mandates.

The Outcome of the Plebiscite

The plebiscite was held to determine the acceptance of the BOL, with significant majority support across affected regions while the Province of Sulu registered a negative vote. The Supreme Court held that the Province of Sulu must be excluded from BARMM as its inclusion contradicted the constitutional directive that only geographic units favorably voting in the plebiscite may be included.

Final Declaration and Ruling

The Supreme Court partially granted the petition of the Province of Sulu

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