Montejo v. Commission on Elections
NEW DOCTRINEFacts
1. The Antecedents: The underlying dispute concerns the redistricting of legislative districts in the province of Leyte, Philippines. Following the conversion of the sub-province of Biliran into a regular province, the existing legislative districts experienced an imbalance in population and registered voters. Petitioner Cirilo Roy G. Montejo, representing the First District of Leyte, sought to address this perceived inequity by proposing a transfer of the municipality of Tolosa from his district to the Second District. 2. Procedural History: The Commission on Elections (COMELEC), in response to the demographic shifts caused by Biliran's provincial conversion, issued Resolution No. 2736 on December 29, 1994. This resolution involved redistricting certain municipalities within Leyte, including the transfer of Capoocan from the Second District and Palompon from the Fourth District to the Third District. Petitioner Montejo subsequently filed a motion for reconsideration, arguing for the transfer of Tolosa from the First to the Second District to equalize voter distribution. This motion was opposed by intervenor Sergio A.F. Apostol and was ultimately denied by the COMELEC. 3. The Petition: Petitioner Montejo filed a petition with the Supreme Court, seeking the annulment of Section 1 of COMELEC Resolution No. 2736. He contended that the resolution violated the constitutional principle of equality of representation, citing Wesberry v. Sanders and arguing that the COMELEC overstepped its authority by engaging in legislative redistricting. The petition specifically requested the transfer of the municipality of Tolosa from the First District to the Second District to rectify the alleged inequity. The Solicitor General concurred with the petitioner's views, while the intervenor argued that the COMELEC lacked jurisdiction and that the resolution was constitutional.
Issue(s)
Whether the COMELEC has the constitutional power to transfer municipalities from one legislative district to another. Whether Section 1 of COMELEC Resolution No. 2736, which transferred municipalities, constitutes grave abuse of discretion amounting to lack of jurisdiction. Whether the issue of reapportionment due to the conversion of Biliran into a regular province is a justiciable question that can be resolved by the Supreme Court.
Ruling
The Supreme Court annulled and set aside Section 1 of COMELEC Resolution No. 2736 insofar as it transferred the municipality of Capoocan from the Second District and the municipality of Palompon from the Fourth District to the Third District of Leyte. The Court denied the petition praying for the transfer of the municipality of Tolosa from the First District to the Second District.
Ratio Decidendi
On the COMELEC's power to redistrict: The Court held that the COMELEC committed grave abuse of discretion amounting to lack of jurisdiction when it promulgated Section 1 of Resolution No. 2736. The Ordinance appended to the 1987 Constitution, which outlines the apportionment of legislative districts, empowers the COMELEC only to make "minor adjustments" to the reapportionment therein made. The debates during the Constitutional Commission clearly indicated that "minor adjustments" referred to correcting forgotten municipalities or errors in names, not transferring entire municipalities between districts. The power to transfer municipalities from one legislative district to another is a legislative power, not an administrative or minor adjustment power vested in the COMELEC. Section 3 of the Ordinance, which allows the COMELEC to adjust the number of members in a province from which a new province was created, pertains to adjusting the number of congressional seats, not the territorial composition of existing districts by transferring municipalities. On the validity of Section 1 of Resolution No. 2736: Consequently, the Court found Section 1 of Resolution No. 2736 void. The COMELEC exceeded its authority by undertaking a substantive redistricting action, which is traditionally a legislative function. While the conversion of Biliran into a regular province created an imbalance in the distribution of inhabitants and voters, potentially devaluing a citizen's vote and raising equal protection concerns, the COMELEC was not the proper body to address this issue through redistricting. The Court emphasized that the power to reapportion legislative districts is explicitly granted to Congress under Section 5(4), Article VI of the Constitution, which mandates Congress to make reapportionment within three years following the return of every census. On the justiciable nature of reapportionment and the Court's role: The Court acknowledged that the validity of a legislative apportionment is a justiciable question, as established in Macias v. COMELEC. However, it clarified that while the Supreme Court can strike down an unconstitutional reapportionment, it cannot undertake the reapportionment itself. Therefore, the Court could not grant petitioner Montejo's request to direct the COMELEC to transfer the municipality of Tolosa from the First District to the Second District. The remedy for such imbalances lies with Congress, which has the sole power to reapportion legislative districts.
Main Doctrine
The Commission on Elections (COMELEC) does not possess the legislative power to redistrict or reapportion legislative districts; its authority is limited to making minor adjustments as expressly provided by law or ordinance. The power to reapportion legislative districts is vested in Congress.