Title
Supreme Court
Umali vs. Commission on Elections
Case
G.R. No. 203974
Decision Date
Apr 22, 2014
Cabanatuan City's conversion to an HUC required a plebiscite involving all Nueva Ecija voters, as the change directly impacted the province, per constitutional mandate.

Case Summary (G.R. No. 203974)

Factual Background

The Sangguniang Panglungsod of Cabanatuan requested the President to convert Cabanatuan from a component city of Nueva Ecija into a Highly Urbanized City (HUC). The President issued Proclamation No. 418, contingent upon approval by plebiscite among qualified voters "therein" as mandated by Section 453 of the LGC. The COMELEC resolved that only registered voters of Cabanatuan City would participate in the plebiscite. Governor Umali filed for reconsideration, arguing that the entire province of Nueva Ecija should vote, invoking constitutional provisions that require participation of voters in all political units "directly affected" by local government changes. The COMELEC denied the motion, leading to the present consolidated petitions.

Legal Issue

The primary legal question is whether the plebiscite for converting Cabanatuan City into a Highly Urbanized City should be participated in solely by the qualified voters of Cabanatuan City or also by the qualified voters of the entire province of Nueva Ecija, which is allegedly directly affected by the conversion.

Supreme Court’s Analysis: Constitutional and Statutory Interpretation

  • Applicable Constitutional Provision: Section 10, Article X of the 1987 Constitution, which requires approval by a majority of votes cast in a plebiscite in the "political units directly affected" by creation, division, merger, abolition, or substantial alteration of boundaries of local government units.
  • Statutory Framework: Section 453 of the LGC mandates the President to declare a city highly urbanized upon meeting requirements and ratification by plebiscite of the qualified voters "therein."
  • The Court held that Section 453 of the LGC must be interpreted in light of Section 10, Article X of the Constitution, the supreme law. The phrase "qualified voters therein" in Section 453 must be read as including all qualified voters of the political units directly affected by the conversion, not only those within the component city.
  • Conversion to a Highly Urbanized City is considered a "substantial alteration of boundaries" since it effectively renders the city independent and outside provincial supervision, thereby reducing the province’s territorial jurisdiction and governance powers.
  • The phrase "boundaries" under the Constitution includes both physical and political boundaries; hence, the conversion substantially alters political boundaries.
  • Precedents such as Miranda v. Aguirre (1999) are analogously applied, which ruled that changes affecting political and economic rights require plebiscitary approval from all directly affected political units.
  • The legislative delegation of authority to the President for city conversion under the LGC is subject to constitutional limits and must comply with the plebiscite mandate covering all directly affected political units.

Impact on Economic and Political Rights of the Province

  • Conversion causes Nueva Ecija to lose approximately 5% of its territory (282.75 sq. km).
  • The Internal Revenue Allotment (IRA) of the province is reduced due to the loss of population and land area metrics used in its calculation, leading to a decrease estimated at over a hundred million pesos.
  • Taxation powers shift to the new HUC, diminishing the province’s revenue sources from local taxes previously collected in Cabanatuan City, including quarry and professional taxes.
  • Politically, the province loses supervisory authority over the city’s government officials, the ability to review or approve local ordinances and executive orders pertaining to the city, and the city’s voters lose their right to vote for provincial elective positions.
  • These changes constitute a material and direct effect upon the province’s economic and political rights, qualifying it as a directly affected political unit entitled to participate in the plebiscite.

Interpretation of “Political Units Directly Affected”

  • Drawing from prior decisions Tan v. COMELEC and Padilla v. COMELEC, the Court determines that all political units whose boundaries are altered and whose economies would be affected must participate in the plebiscite.
  • The constitutional provision anticipates inclusion of multiple affected units, not singular municipal or city units, where the alteration impacts a broader political entity.
  • The Court notes legislative and Constitutional Commission discussions affirming that political units directly affected encompass all politically and economically impacted LGUs, which in this case includes the entire province of Nueva Ecija.

Rejection of Respondents’ Position

  • Respondents argued the plebiscite should be limited to voters within Cabanatuan City, citing interpretations of Section 453 of the LGC and past precedents where only city residents voted.
  • The Court finds that those precedents did not address the constitutional issue or involve a contested interpretation and are therefore not binding or dispositive in the present controversy.
  • Interpreting Section 453 in isolation leads to conflict with the constitutional requirement. Consequently, the Court harmonizes Section 453 with Article X, Section 10 to avoid unconstitutional reading, expanding the plebiscite electorate to all qualified voters in political units directly affected, namely the entire province.
  • The Court dismisses concerns that requiring provincial participation in the plebiscite undermines city autonomy or sets an illegitimate precedent; rather, it underscores democratic participation and majority rule where rights and responsibilities materially change.

Disposition

  • The petition for certiorari is granted. COMELEC’s Minute Resolutions No. 12-0797 and No. 12-0925 are declared null and void. COMELEC is enjoined from implementing these resolutions.
  • COMELEC is ordered to conduct the plebiscite for conversion of Cabanatuan City into a Highly Urbanized City, including all qualified registered voters of the Province of Nue

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