Subido v. Lood
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the validity and constitutionality of certain provisions of Republic Act No. 6132, an implementing legislation for a Constitutional Convention. Specifically, the petitioners challenge Section 4, which deems public officials and employees resigned upon filing a certificate of candidacy, and Section 8(a), paragraph 2, which prohibits certain heads of executive departments, bureaus, offices, and government-owned or controlled corporations from intervening in or supporting/opposing campaigns for delegate. 2. Procedural History: These cases were filed with the Supreme Court as petitions for declaratory relief, pursuant to Section 19 of Republic Act 6132. The Solicitor General filed the corresponding answers. Hearings were held, and oral arguments were presented by the parties and amici curiae. The Supreme Court is now resolving these consolidated petitions. 3. The Petition: The petitioners, who are government officials and employees, assail the validity of Section 4 and, in one case, Section 8(a), paragraph 2, of Republic Act No. 6132. They argue that these provisions are inconsistent with Section 3 of Resolution No. 2 (passed by Congress as a constituent assembly) and violate the proviso in Section 8 of Resolution No. 2, which mandates that implementing legislation must not be inconsistent with the Resolution. They contend that Congress, acting as a legislative body, cannot validly amend a Resolution passed by it as a constituent assembly. Furthermore, they argue that Section 4 constitutes class legislation, denying equal protection by disqualifying public officials and employees from serving as delegates by considering them resigned, a disqualification not applied to those in private enterprises.
Issue(s)
Whether Sections 4 and 8(a), paragraph 2, of Republic Act No. 6132 are valid and constitutional. Whether Section 4 of Republic Act No. 6132 constitutes class legislation and denies equal protection. Whether Congress, acting as a legislative body, can validly amend a Resolution passed by it as a constituent assembly.
Ruling
The Court resolved to deny the prayers in the petitions and declared that Sections 4 and 8(a), paragraph 2, of Republic Act No. 6132 are not invalid or unconstitutional.
Ratio Decidendi
On the validity of Sections 4 and 8(a), paragraph 2, of Republic Act No. 6132: The Court held that Section 3 of Resolution No. 2, stating that the office of Delegate shall be honorary and compatible with any other public office, is a mere declaration and does not preclude Congress from imposing restrictions. The Court found no inconsistency between Section 3 of Resolution No. 2 and Section 4 of Republic Act No. 6132, as the latter provision, along with Section 8(a), paragraph 2, aligns with Section 2, Article XII of the Constitution, which prohibits civil service employees and members of the armed forces from engaging in partisan political activities or taking part in elections except to vote. The Court noted that the original Resolution No. 2, in Section 2, provided for the election of Delegates in accordance with the Revised Election Code, which explicitly states that appointive officers and employees are ipso facto considered resigned upon filing their certificates of candidacy, and elective officials are considered resigned from their current office. While this clause was omitted in Resolution No. 4, it indicated the intent of Congress as a constituent assembly, and its omission was meant to be filled by implementing legislation, as was done by Section 4 of Republic Act No. 6132, in conformity with Section 8 of Resolution No. 2. Therefore, the implementing legislation did not amend the Resolution but rather provided the necessary details consistent with its spirit and existing constitutional prohibitions. On whether Section 4 of Republic Act No. 6132 constitutes class legislation and denies equal protection: The Court ruled that Section 4 does not constitute discriminatory legislation. It reasoned that the classification of government officials and employees, as opposed to persons in private enterprises, is germane to the purpose of the Act and is based on substantial differences. The Court cited the principle that legislation affecting all persons of the same class equally, without affecting others, is not class legislation if the classification is reasonable and based on apparent differences. The Court further explained that public officials and employees are not absolutely barred from becoming Delegates; they are merely required to relinquish their positions. This condition is imposed for public interest, as certain government offices offer advantages that could be used to enhance candidacies, contrary to the equal protection clause. Additionally, allowing them to campaign and serve as Delegates without vacating their positions would be detrimental to public service, depriving the government of their services without the positions being filled. On whether Congress, acting as a legislative body, can validly amend a Resolution passed by it as a constituent assembly: The Court implicitly addressed this by finding that the implementing legislation (Republic Act No. 6132) was consistent with the Resolution (Resolution No. 2 as amended by Resolution No. 4). The Court viewed the provisions of Republic Act No. 6132 as details filling in the framework established by the Resolutions, rather than amendments that altered the substance of the constituent assembly's work. The Court emphasized that the implementing legislation must not be inconsistent with the provisions of the Resolution, and in this case, it was found to be in accord with the spirit and intent of the Resolutions and existing constitutional provisions.
Main Doctrine
Sections 4 and 8(a), paragraph 2, of Republic Act No. 6132, which require public officials and employees to resign upon filing their certificates of candidacy for Delegate to the Constitutional Convention and prohibit certain heads of executive departments and officials from intervening in the nomination or campaign of candidates, are valid and constitutional.