Leyva v. Commission on Elections
REITERATIONFacts
The Antecedents: Republic Act No. 4413, creating the City of Rajah Buayan, stipulated that it would take effect on January 1, 1966, if a majority of the qualified voters of the Municipality of General Santos accepted it in a plebiscite to be held on November 9, 1965. The plebiscite was held jointly with the national elections. The results showed 15,727 registered voters, 9,192 who actually voted in the election, 7,488 who voted for or against conversion, 4,422 in favor, and 3,066 against. Procedural History: The Commission on Elections (COMELEC) proclaimed the creation of the city on December 6, 1965, finding that the affirmative votes represented a majority of the votes cast in the plebiscite. Petitioners, residents and property owners who voted against conversion, challenged the proclamation before the COMELEC, which denied their petition. Petitioners then appealed to the Supreme Court. The Petition: Petitioners sought to annul the COMELEC's proclamation and resolution, arguing that the conversion of the municipality into a city was not accepted by a majority of the qualified voters as required by Republic Act No. 4413.
Issue(s)
Whether the phrase "majority of the qualified voters" in Section 92 of Republic Act No. 4413 refers to the majority of the registered voters or the majority of those who actually voted in the plebiscite. Whether the proclamation of the creation of the City of Rajah Buayan was valid.
Ruling
The Supreme Court granted the petition, annulled the proclamation of the Commission on Elections, and made permanent the preliminary injunction. The Court ruled that the charter of the City of Rajah Buayan was not duly accepted by the majority of the qualified voters of the municipality of General Santos as provided in Republic Act No. 4413.
Ratio Decidendi
On the interpretation of "majority of the qualified voters": The Court held that the phrase "majority of the qualified voters" unequivocally means the majority of the registered voters. It rejected the interpretation that it meant "majority of the votes cast" as adopted by the Commission on Elections. The Court reasoned that the number of qualified voters should not be an amorphous and variable factor, changing with the whims of individual voters or fortuitous circumstances. The Revised Election Code, specifically Sections 2, 96, and 176(f), establishes that a voter must be registered to be qualified, and the registry list is conclusive regarding the right to vote. Therefore, "qualified voters" is equivalent to "registered voters." To hold otherwise would render the registration process meaningless and create an absurd situation where a registered voter might not be qualified simply because they did not vote, or vice versa. The Court emphasized that the language of Republic Act No. 4413, requiring acceptance by a "majority of the qualified electors," implies a positive vote in the affirmative from all those entitled to vote, not merely a majority of those who actually cast their ballots. The Court found support in decisions from the Supreme Courts of Missouri and Wyoming, which interpreted similar phrases to mean a majority of all legal voters entitled to vote, not just those present or voting. On the validity of the proclamation: Based on the interpretation that "majority of qualified voters" means "majority of registered voters," the Court found that the affirmative votes (4,422) did not constitute a majority of the 15,727 registered voters in General Santos. Consequently, the condition for the effectivity of Republic Act No. 4413 was not met, rendering the proclamation of the creation of the City of Rajah Buayan invalid.
Main Doctrine
The phrase "majority of the qualified voters" in a plebiscite provision refers to the majority of the registered voters, not the majority of those who actually voted.