Rosario v. Carbonell
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the constitutionality of Republic Act No. 6132, an act implementing resolutions calling for a Constitutional Convention. Simeon G. del Rosario, the petitioner, challenges the law in its entirety, questioning its provisions related to the convention's purpose, funding, and the process of amending or revising the Constitution. 2. Procedural History: This case originated as a petition for declaratory relief filed by Simeon G. del Rosario against Ubaldo Carbonell, Jaime N. Ferrer, Lino Patajo, and Cesar Milaflor, who were respondents in their official capacities. The petition sought to have Republic Act No. 6132 declared unconstitutional. The Solicitor General filed an answer on behalf of the respondents. The Supreme Court has previously ruled on the constitutionality of various sections of R.A. No. 6132 in related cases. 3. The Petition: Petitioner Simeon G. del Rosario, invoking Section 19 of R.A. No. 6132, filed a petition for declaratory relief seeking to declare the entire R.A. No. 6132 unconstitutional. He argued that the appropriation of twenty-nine million pesos was a waste of public funds due to the lack of a time limit for the Constitutional Convention. He also challenged the title of the law for allegedly embracing more than one subject, violating a constitutional provision. The petition also raised concerns about the potential for the convention to propose amendments or entirely new constitutions, and the implications of candidates including statements of constitutional reforms. The Supreme Court, however, found that the petitioner lacked sufficient averments regarding his specific rights being affected, except for his interest as a taxpayer concerning the appropriation. The Court also noted previous rulings upholding the constitutionality of various provisions of the law.
Issue(s)
Whether Republic Act No. 6132 is unconstitutional. Whether the title of Republic Act No. 6132 embraces more than one subject.
Ruling
The Supreme Court denied the prayer in the petition and declared Republic Act No. 6132 as constitutional. The petition was dismissed.
Ratio Decidendi
On the issue of the constitutionality of Republic Act No. 6132 and the petitioner's standing: The Court found that the petitioner's averments were insufficient to establish a clear right that would be affected by the law, particularly concerning his status as a temporary staff writer and foreign service officer. However, his interest as a taxpayer in contesting the appropriation of funds for the Constitutional Convention was sustained, as he alleged it was a waste of public funds. The Court also noted that the necessity of amending the Constitution is a matter addressed to the wisdom of Congress, and any proposed new constitution, regardless of its nature, would be submitted to the people for ratification, making its validity dependent on popular approval. The Court reiterated its previous rulings in Imbong vs. Ferrer and Gonzales vs. Ferrer, which upheld the constitutionality of R.A. No. 6132 and its specific sections. On the issue of the title of Republic Act No. 6132: The Court found the title of Republic Act No. 6132 to be constitutional. The title, "An Act Implementing Resolution of Both Houses Numbered Two as Amended by Resolution of Both Houses Numbered Four of the Congress of the Philippines Calling for a Constitutional Convention, Providing for Proportional Representation Therein and Other Details Relating to the Election of Delegates to and the Holding of the Constitutional Convention, Repealing for the Purpose Republic Act Four Thousand Nine Hundred Fourteen, and for Other Purposes," was deemed sufficient. The Court held that the phrase "To propose amendments to the Constitution of the Philippines" was implicitly contained within the title and the resolutions it implemented, making its explicit inclusion superfluous. The Court reiterated the principle that a title need not be an exhaustive index of the law's provisions but must fairly indicate the general subject and reasonably cover all provisions without misleading Congress or the public. All details within R.A. No. 6132 were found to be germane to its title.
Main Doctrine
The Supreme Court upheld the constitutionality of Republic Act No. 6132, finding that its title adequately covered its subject matter and that the appropriation of funds for the Constitutional Convention was a valid exercise of legislative power. The Court reiterated that the necessity for constitutional amendments and the scope of a Constitutional Convention are matters of legislative discretion and ultimately subject to the ratification of the sovereign people, thus precluding judicial intervention on such grounds.