Case Summary (G.R. No. 210328)
Applicable Law
The primary legal framework governing this case is the Local Government Code of 1991, as well as the provisions of the 1987 Philippine Constitution, given the decision was rendered in 1999.
Arguments of the Petitioner
Petitioner Moises S. Samson challenges the constitutionality of Republic Act No. 8535 on two main grounds:
- The law allegedly does not meet the requirements specified in Sections 7, 11(a), and 450(a) of the Local Government Code concerning income, population, land area, and lack of adverse effects on Quezon City.
- He claims that the enactment of R.A. No. 8535 constitutes an amendment to the Constitution.
Samson asserts that during the congressional deliberations, no certifications concerning the required income, population, and land area were presented, nor was there evidence that Quezon City would not be adversely affected by the change.
Respondents’ Position
In response, the respondents, represented by the Office of the Solicitor General, argue that the petitioner has failed to provide sufficient evidence to substantiate his claims. They assert that the petitioner bears the burden of proof to overcome the presumption of constitutionality that every statute enjoys. The respondents contend that this presumption includes a belief that all legal requirements were adequately considered during the legislative process leading to the passage of R.A. No. 8535.
Judicial Presumptions and Burden of Proof
Referencing the case of Victoriano v. Elizalde Rope Workers Union, the court emphasizes that statutory presumptions favor constitutionality and that a challenger must prove unconstitutionality beyond a reasonable doubt. Every legislative act is presumed to pass through regular congressional procedures, thus placing the obligation on the petitioner to provide clear and convincing evidence to the contrary.
Analysis of Compliance with Local Government Code
The court examined the requirements of the Local Government Code of 1991, particularly Section 7, which mandates that the creation of a local government unit should rely on "verifiable indicators of viability," including sufficient income, a defined population, and land area specifications. Respondents established that average annual income estimates presented during Senate hearings exceeded the minimum threshold, with the population figures substantially above the requirement, making it unnecessary for the court to further evaluate the land area requirement.
Consideration of Legislative Hearings and Certificates
While the petitioner claims that no formal certifications accompanied the bill presented to the Congress, the court observed that the controversy began in the House of Representatives, where it was sponsored by Cong. Dante Liban. The hearings featured testimonies from various government officials regarding the relevant statistics. The court determined that oral confirmations from these officials hold significant value, constituting substantial compliance with the laws' requirements.
Seat of Government Provisions
The petitioner raised concerns regarding the lack of specification of a seat of government within R.A. No. 8535. However, the court stated that such an omission does not invalidate the law. According to Section 12 of the Local Government Code, the City of Novaliches could later establish such a seat. The law allows for the establishment of a government center post-creation, suggesting that the law does not lack foundational soundness.
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Background of the Case
- On February 23, 1998, President Fidel V. Ramos enacted Republic Act No. 8535, which established the City of Novaliches from 15 barangays of Quezon City.
- Petitioner Moises S. Samson, the incumbent councilor of Quezon City's first district, challenges the constitutionality of R.A. No. 8535.
- Samson seeks to prevent the Executive Secretary from executing R.A. 8535, the Commission on Elections (COMELEC) from conducting a plebiscite for the City's creation, and the Department of Budget and Management from allocating funds for said plebiscite.
- He requests a preliminary injunction or temporary restraining order.
Grounds for the Petition
- Petitioner asserts that R.A. No. 8535 does not conform to the Local Government Code's criteria regarding income, population, land area, seat of government, and potential adverse effects on Quezon City.
- He claims there were no certifications on income, population, and land area presented to Congress during the legislative process.
- Samson also argues that the law effectively amends the Constitution.
Respondents' Position
- The respondents, represented by the Office of the Solicitor General, refute petitioner's allegations, contending that he provided insufficient evidence to support his claims.
- They assert that the petitioner bears the burden of proof against the presumption that Congress fulfilled all legal requirements when enacting R.A. 8535.
- The respondents urge the Court to dismiss the petition due to lack of merit.
Legal Presumptions and Standards
- Referencing Victoriano v. E