Macias v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioners, members of the House of Representatives and a provincial governor, sought to prevent the implementation of Republic Act 3040, an act apportioning representative districts in the Philippines. They alleged the law was unconstitutional for several reasons: (a) it was passed without printed final copies of the bill being furnished to members at least three calendar days prior to passage; (b) it was approved more than three years after the return of the last census; and (c) it apportioned districts without regard to the number of inhabitants. Procedural History: Respondents, the Commission on Elections and the National Treasurer, averred they were merely complying with their duties under the statute, which they presumed to be constitutional. They also raised issues of petitioners' personality to sue and the presumption of constitutionality of duly certified laws. The Petition: The Supreme Court, in a prior resolution, had already issued an injunction, finding that Republic Act 3040 violated constitutional provisions regarding proportional representation, citing specific examples of unequal apportionment between provinces with differing populations. This extended opinion was written to fully explain the premises for that conclusion.
Issue(s)
Whether petitioners have the legal personality to file the action. Whether Republic Act 3040 was passed in accordance with the constitutional requirement of furnishing printed copies of the bill to members at least three calendar days prior to its passage. Whether the apportionment of representative districts in Republic Act 3040 was based on a valid census return. Whether Republic Act 3040 violated the constitutional mandate to apportion Members of the House of Representatives among the several provinces as nearly as may be according to the number of their respective inhabitants. Whether the issue of legislative apportionment is a political question non-justiciable by the courts.
Ruling
The Supreme Court reiterated its resolution declaring Republic Act 3040 void for infringing upon the provisions of the Constitution. The injunction previously issued was maintained.
Ratio Decidendi
On the Personality of the Petitioners: The petitioners, as voters and as congressmen and governor of aggrieved provinces, have sufficient interest to question the validity of the apportionment act. Citizens deprived of their full and effective elective franchise by an apportionment act have standing to test its statute, as they have the right to have the State apportioned in accordance with the Constitution and to be governed by a Legislature fairly representing the whole body of the electorate. The reliance on Colegrove v. Green was deemed inconclusive. On the Printed-Form, Three-Day Requirement: The Court found it unnecessary to make a definitive pronouncement on whether the bill was passed without the required printed copies being furnished three days prior to passage, as the controversy could be decided on the issue of districts-in-proportion-to-inhabitants. However, the constitutional provision serves a fundamental purpose, and the enrolled-bill theory, if adopted, could preclude courts from enforcing this requirement. On the Population Census: The Court noted that while the apportionment was based on a preliminary census report that was subject to revision, authorities sustain the view that such a report can be considered official for purposes of governmental action, including apportionment. This issue did not clearly favor the petitioners, as governmental action could be based on such a report according to cited cases. On the Apportionment of Members: The Court found that Republic Act 3040 violated the constitutional directive to apportion Members of the House of Representatives according to the number of inhabitants. Numerous instances of disproportionate representation were cited, where provinces with larger populations received fewer representatives than those with smaller populations. Such disproportion has been held sufficient to avoid apportionment laws in other jurisdictions, being considered arbitrary and capricious and against the principle of equality. On the Political Question Doctrine: The Court held that the constitutionality of a legislative apportionment act is a judicial question, not a political one, and is subject to judicial review. The passage of apportionment acts is not so exclusively within the political power of the legislature as to preclude court inquiry. The mere impact of a suit on the political situation does not render it political instead of judicial. An unconstitutional apportionment law may be declared void by the courts, even if it is an exercise of political power, as the judiciary cannot stand by and give free rein to the discretion of political departments when constitutional limitations are transgressed.
Main Doctrine
Republic Act 3040, which apportioned representative districts without regard to the number of inhabitants and in violation of the constitutional mandate for proportional representation, is declared void. The judiciary has the power to review the constitutionality of legislative apportionment acts.