Imbong v. Ferrer
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the constitutionality of Republic Act No. 6132, also known as the Constitutional Convention Act of 1970. This law was enacted to implement Congressional Resolutions No. 2 and No. 4, which called for a Constitutional Convention to propose amendments to the existing constitution. Petitioners, who are members of the Bar, taxpayers, and aspiring candidates for delegate to this convention, challenged the validity of the Act, arguing it prejudiced their rights. 2. Procedural History: The case originated from two separate but related petitions for declaratory relief filed by Manuel B. Imbong and Raul M. Gonzales. These petitions were filed pursuant to Section 19 of R.A. No. 6132. After the Solicitor General filed answers on behalf of the respondents (the Chairman and members of the Commission on Elections), hearings were held, including oral arguments from the petitioners and amici curiae. The Supreme Court then considered the consolidated petitions. 3. The Petition: The petitions, filed under the original jurisdiction of the Supreme Court, sought a declaratory judgment on the constitutionality of R.A. No. 6132. Petitioner Raul M. Gonzales assailed the entire law, as well as specific provisions including Sections 2, 4, 5, and paragraph 1 of Section 8(a). Petitioner Manuel B. Imbong challenged only paragraph 1 of Section 8(a) on grounds similar to those raised by Gonzales. The core arguments revolved around alleged violations of due process, equal protection, freedom of expression, assembly, and association, as well as issues of apportionment and disqualification of delegates.
Issue(s)
Whether Republic Act No. 6132, enacted by Congress acting as a legislative body, is constitutional. Whether Section 4 of R.A. No. 6132, which deems public officers and employees resigned upon filing their certificates of candidacy, is constitutional. Whether Section 5 of R.A. No. 6132, disqualifying elected delegates from running for or assuming other public offices until after the adjournment of the Convention, is constitutional. Whether paragraph 1 of Section 8(a) of R.A. No. 6132, prohibiting political parties and organizations from intervening in the nomination or campaign of delegates, is constitutional. Whether Section 2 of R.A. No. 6132, concerning the apportionment of delegates, violates the Constitution.
Ruling
The Supreme Court denied the prayers in both petitions and declared Republic Act No. 6132, including Sections 2, 4, 5, and 8(a), paragraph 1, as constitutional. No costs were awarded.
Ratio Decidendi
On the constitutionality of R.A. No. 6132 enacted by Congress as a legislative body: The Court affirmed that Congress, acting as a legislative body, possesses broad law-making authority. While the power to call a constitutional convention and set fundamental details like qualifications and apportionment rests with Congress acting as a Constituent Assembly, the enactment of implementing details falls within the competence of Congress as a legislative body. This authority is recognized even when the Constituent Assembly omits such details, as provided in Resolution No. 2 as amended by Resolution No. 4. The Court noted that any potential conflict with the President's veto power is not insurmountable, as Congress can override it or reconvene as a Constituent Assembly. On Section 4 of R.A. No. 6132 (resignation of public officers upon filing candidacy): The Court reiterated its previous ruling that this provision is constitutional. It was found to be an application of the prohibition in Section 2 of Article XII of the Constitution and did not constitute a denial of due process or equal protection. This aligns with established jurisprudence that the State can impose qualifications and inhibitions on public officers. On Section 5 of R.A. No. 6132 (disqualification of delegates): The Court upheld this provision, stating that citizens do not have an inherent right to public office, and the State can define qualifications and impose inhibitions. The disqualification was deemed a valid exercise of police power, intended to insulate delegates from self-interest and ensure their dedication to formulating the supreme law. The temporary nature of the disqualification, lasting only until the convention's adjournment, was noted. The Court found the classification of delegates to be based on substantial distinctions germane to the law's purpose and applied to all members of the class, thus not violating equal protection. On Section 2 of R.A. No. 6132 (apportionment of delegates): The Court found no constitutional violation. It clarified that the Constitution does not expressly or impliedly require the apportionment of convention delegates to be strictly based on population in each congressional district, unlike the apportionment of representative districts. The Court found the apportionment in R.A. No. 6132 to be a reasonable implementation of Resolution No. 4, which mandated apportionment based on inhabitants with a minimum of two delegates per district. The use of a preliminary census and a specific formula was deemed reasonable and substantially proportional, acknowledging that absolute proportional representation is not always possible. The Court distinguished this case from Macias et al. vs. Comelec where an unconstitutional apportionment was found. On paragraph 1 of Section 8(a) of R.A. No. 6132 (prohibition on party/organization intervention): The Court affirmed the constitutionality of this provision, viewing it as a valid exercise of police power to prevent the debasement of the electoral process and ensure equality of chances among candidates. The prohibition was narrowly tailored, allowing individual expression and assembly, and preserving the right of individuals to support candidates. The Court reasoned that the ban is necessary to prevent undue influence from political parties and organizations, ensuring delegates are beholden only to the nation. This promotes social justice by providing equal opportunity and equality before the law, allowing candidates to rely on their merits rather than organizational backing. The Court found the ban germane to the objectives of averting electoral debasement and achieving real equality of chances.
Main Doctrine
Republic Act No. 6132, known as the Constitutional Convention Act of 1970, is constitutional. Congress, acting as a legislative body, has the authority to enact implementing details for a Constitutional Convention called by it acting as a Constituent Assembly. Specific provisions regarding the apportionment of delegates, disqualification of delegates from running for other offices, and restrictions on political party intervention in campaigns are valid exercises of legislative power and do not violate constitutional guarantees.