Aldaba v. Commission on Elections
NEW DOCTRINEFacts
The Antecedents: Before May 1, 2009, the province of Bulacan was represented by four legislative districts. The First Legislative District included Malolos City and several municipalities. Republic Act No. 9591 (RA 9591), enacted on May 1, 2009, amended Malolos City's Charter to create a separate legislative district for the city. At the time the relevant bills were filed in 2007, Malolos City's population was 223,069. A contested fact is its population on May 1, 2009, though a National Statistics Office (NSO) certification projected the population to be 254,030 by 2010, based on a 3.78% growth rate between 1995 and 2000. Procedural History: Petitioners, identified as taxpayers, registered voters, and residents of Malolos City, filed an original action for Prohibition with the Supreme Court. They challenged the constitutionality of RA 9591. The Office of the Solicitor General (OSG), representing the Commission on Elections, argued that Congress's use of projected population figures for legislative district creation is a non-justiciable political question concerning the wisdom of the legislative standard. The Petition: The petitioners contend that RA 9591 is unconstitutional because it violates Section 5(3), Article VI of the 1987 Constitution and Section 3 of the Ordinance appended to the Constitution, which require a city to have a population of at least 250,000 to merit its own legislative district. They argue that the NSO certification relied upon is invalid because it was issued by a Regional Director without proper authority, was not based on projections declared official by the National Statistics Coordination Board (NSCB), and did not reflect the population as of the middle of the year. Furthermore, based on the stated population and growth rate, Malolos City's population would not reach 250,000 by the 2010 elections.
Issue(s)
Whether Republic Act No. 9591 is unconstitutional for creating a legislative district for Malolos City despite its alleged failure to meet the minimum population requirement. Whether the projected population figures used to justify the creation of the legislative district are legally valid and sufficient. Whether the determination of compliance with constitutional population requirements for legislative districts is a justiciable issue.
Ruling
The Supreme Court granted the petition and declared Republic Act No. 9591 unconstitutional. The Court held that Malolos City did not meet the constitutional requirement of having a population of at least 250,000 to be entitled to its own legislative district.
Ratio Decidendi
On the constitutionality of RA 9591 and the population requirement: The Court reiterated that Section 5(3), Article VI of the 1987 Constitution requires a city to have a population of at least 250,000 to be entitled to its own legislative district. Section 3 of the Ordinance appended to the 1987 Constitution further clarifies that a city attaining such population is entitled to representation in the "immediately following election." The Court found no official record showing that Malolos City had attained or would attain a population of 250,000, actual or projected, before the May 10, 2010 elections, which was the immediately following election after the supposed attainment of such population. Therefore, Malolos City was not qualified to have its own legislative district. On the validity of projected population figures: The Court found the undated Certification of Regional Director Alberto N. Miranda of the NSO to be without legal effect. Firstly, certifications on demographic projections can only be issued if declared official by the National Statistics Coordination Board (NSCB), and such certifications can only be issued by the NSO Administrator or a designated certifying officer. Regional Director Miranda had no basis or authority to issue the certification, and it was not shown that his projections were declared official by the NSCB. Secondly, Executive Order No. 135 mandates that intercensal population projections must be as of the middle of every year, which the certification failed to meet. Thirdly, based on the certification's own growth rate assumption of 3.78% between 1995-2000, the population of Malolos in 2000 (175,291) would only grow to 241,550 by 2010, which is less than the required 250,000. Even using the 2007 Census population of 223,069 and the same growth rate, the projected population for 2010 would still be below 250,000. Thus, the projected population figures were unreliable and speculative. On the justiciability of compliance with constitutional standards: The Court rejected the contention that the legislative branch's choice of means to comply with population requirements is non-justiciable. It held that questions requiring judicial determination of compliance with constitutional standards by other branches of government are fundamentally justiciable. This falls within the Court's checking function to determine if there has been a grave abuse of discretion amounting to lack or excess of jurisdiction. The Court cited precedent, even from the 1935 Constitution, affirming that district apportionment laws are subject to judicial review to ensure compliance with constitutional standards aimed at equalizing population and voting power among districts.
Main Doctrine
Republic Act No. 9591, which created a legislative district for Malolos City, is unconstitutional for failing to meet the minimum population requirement of 250,000 for a city to have its own legislative district, as mandated by the Constitution and its appended Ordinance.