Aquino v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioners Senator Benigno Simeon C. Aquino III and Mayor Jesse Robredo sought the nullification of Republic Act No. 9716, which reapportioned the first and second legislative districts of Camarines Sur to create a new legislative district. The law, enacted on October 12, 2009, took effect on October 31, 2009. Prior to Republic Act No. 9716, Camarines Sur had four legislative districts. The reapportionment reconfigured the first and second districts, resulting in a new first district with a population of 176,383, a new second district with 276,777, and the former second district becoming the new third district with 439,043. Procedural History: The case was filed before the Supreme Court via a Petition for Certiorari and Prohibition under Rule 65 of the Rules of Court, seeking to nullify Republic Act No. 9716 and restrain the Commission on Elections (COMELEC) from implementing it. The Petition: Petitioners contended that Republic Act No. 9716 was unconstitutional for violating the explicit constitutional standard requiring a minimum population of 250,000 for the creation of a legislative district, as they interpreted Section 5(3), Article VI of the 1987 Constitution. They argued that the new first district, with only 176,383 inhabitants, failed to meet this requirement. They also claimed the law violated the principle of proportional representation.
Issue(s)
Whether the petition for Certiorari and Prohibition under Rule 65 is the proper remedy, and whether the petitioners have the legal standing (locus standi) to question the constitutionality of Republic Act No. 9716. Whether Republic Act No. 9716, which created a new legislative district in Camarines Sur with a population of 176,383, violates Section 5(3), Article VI of the 1987 Constitution requiring a minimum population of 250,000 for the creation of a legislative district. Whether the 250,000 population requirement in Section 5(3), Article VI of the Constitution applies only to cities seeking to be entitled to a representative, and on the factors considered in reapportionment. Whether Republic Act No. 9716 violates the principle of proportional representation, and whether there was grave abuse of discretion.
Ruling
The petition is dismissed. Republic Act No. 9716 is declared a VALID LAW.
Ratio Decidendi
On the propriety of the remedy and locus standi: The Court held that while there might be procedural defects in the petition (choice of remedy and locus standi), it would set aside these technicalities due to the transcendental importance of the issues raised. The Court has consistently relaxed procedural rules and the requirement of locus standi when faced with issues of paramount public importance that have pervasive influence on the social and moral well-being of the nation. The Court cited previous cases like Del Mar v. Philippine Amusement and Gaming Corporation (PAGCOR) and Jaworski v. PAGCOR to justify taking original cognizance of the case and excusing the lack of direct injury when an issue of transcendental importance is presented, as in Kilosbayan v. Guingona and Tatad v. Executive Secretary. On the constitutional requirement of 250,000 population for legislative districts: The Court ruled that there is no specific provision in the Constitution that fixes a 250,000 minimum population that must compose a legislative district in a province. The petitioners' reliance on Section 5(3), Article VI of the Constitution was misinterpreted. The provision states: "Each city with a population of at least two hundred fifty thousand, or each province, shall have at least one representative." The Court emphasized that the use of a comma clearly distinguishes the requirement for cities from that for provinces. While a city must have at least 250,000 inhabitants to be entitled to a representative, a province is entitled to at least one representative by its very creation, regardless of population. The 250,000 benchmark was established for the initial apportionment of seats among provinces and cities, not as an absolute minimum for every subsequent district created within a province. On the interpretation of Section 5(3), Article VI of the Constitution and factors considered in reapportionment: The Court clarified that the 250,000 population requirement in Section 5(3), Article VI of the Constitution applies only to cities seeking to be entitled to a representative. For provinces, the Constitution simply states that each province shall have at least one representative, without a specified population threshold. This interpretation was consistent with the Court's ruling in Mariano, Jr. v. COMELEC, which dealt with the creation of an additional legislative district within a city. The Court noted that the records of the Constitutional Commission reveal that while population was a determinant for the initial apportionment of legislative seats, the creation of districts within provinces involved other factors. These factors included contiguity, compactness, adjacency, common interests, geographical divisions, political stability, and even considerations like the importance of towns and cities. The districting of Palawan and Benguet/Baguio City, as narrated in the Constitutional Commission's journals, demonstrated that population was not the sole determinant and could be disregarded in favor of other practical considerations. Therefore, the reapportionment made by Republic Act No. 9716, which considered factors such as dialects, size of groupings, natural divisions, and balancing of areas, was valid even if the new district had a population of 176,383. On the absence of grave abuse of discretion and the principle of proportional representation: The Court concluded that the factors considered in the reapportionment of Camarines Sur's legislative districts, when taken together, showed no abuse of discretion, much less grave abuse of discretion, that would warrant the invalidation of Republic Act No. 9716. The Court reiterated that population is not the only factor but is just one of several other factors in the composition of an additional legislative district, aligning with both the text and spirit of the Constitution.
Main Doctrine
The creation of a new legislative district in a province does not require a minimum population of 250,000 as mandated by Section 5(3), Article VI of the Constitution, which specifically applies only to cities. The apportionment of legislative districts in provinces may consider other factors besides population, such as contiguity, compactness, adjacency, common interests, and geographical divisions, provided there is no grave abuse of discretion.