Navarro v. Ermita
REVERSALFacts
The Antecedents: The case concerns the constitutionality of Republic Act No. 9355, which created the Province of Dinagat Islands. The law was enacted on October 2, 2006, and subsequently ratified in a plebiscite on December 3, 2006. The creation of the new province led to the appointment and election of its own provincial officials, separating it from the mother province of Surigao del Norte. Procedural History: Initially, a petition challenging the constitutionality of R.A. No. 9355 was dismissed by the Supreme Court on technical grounds. Undeterred, petitioners filed a second petition, arguing that the creation of Dinagat Islands violated constitutional and statutory requirements regarding land area and population for the establishment of a new province. The Supreme Court initially granted this petition, declaring R.A. No. 9355 unconstitutional. Subsequent motions for reconsideration by the Republic and Dinagat were denied. Later, intervenors, who were elected officials of Surigao del Norte, sought to recall the entry of judgment and file their own motion for reconsideration, arguing their election would be nullified if the original decision stood. The Court granted their motion to recall the entry of judgment and reconsidered its previous rulings. The Petition: The intervenors, elected officials of Surigao del Norte, filed an Urgent Motion to Recall Entry of Judgment and sought to intervene in the case. They argued that their election to office would be nullified if Dinagat Islands reverted to being part of Surigao del Norte, as per the original Supreme Court decision. They contended that the creation of Dinagat Islands was an amendment to the Local Government Code, that the land area requirement should not apply to island provinces, and that the Operative Fact Doctrine was applicable. Their petition, in essence, sought to uphold the validity of R.A. No. 9355 and the existence of the Province of Dinagat Islands, thereby preserving their elected positions and preventing the disruption of the newly created province.
Issue(s)
Whether the Court should recall the entry of judgment and allow the movants-intervenors to intervene. Whether Republic Act No. 9355, creating the Province of Dinagat Islands, is constitutional. Whether the land area requirement for the creation of a province under Section 461 of the Local Government Code is absolute, or if the exemption for island territories provided in the Implementing Rules and Regulations (IRR) is valid.
Ruling
The Court GRANTED the Urgent Motion to Recall Entry of Judgment, RECONSIDERED and SET ASIDE the July 20, 2010 Resolution, GRANTED the Motion for Leave to Intervene, and GRANTED the Intervenors’ Motion for Reconsideration of the May 12, 2010 Resolution. The May 12, 2010 Resolution was RECONSIDERED and SET ASIDE. The provision in Article 9(2) of the Rules and Regulations Implementing the Local Government Code of 1991, stating "The land area requirement shall not apply where the proposed province is composed of one (1) or more islands," was declared VALID. Consequently, Republic Act No. 9355 was declared VALID and CONSTITUTIONAL, and the proclamation of the Province of Dinagat Islands and the election of its officials were declared VALID. The petition was DISMISSED.
Ratio Decidendi
On the recall of entry of judgment and intervention: The Court found that the movants-intervenors had a personal and substantial interest in the case that arose after the initial judgment, particularly due to COMELEC Resolution No. 8790, which stipulated the nullification of election results if the decision became final and executory after the elections. Denying their motion would leave them without remedy and violate their right to due process. The Court invoked the "moot and academic" principle exceptions, specifically the paramount public interest and the exceptional character of the situation, to allow intervention despite the entry of judgment. The Court emphasized its role as a court of justice and equity, weighing the dire repercussions of the controversy on the movants-intervenors. On the constitutionality of R.A. No. 9355 and the land area requirement: The Court held that the exemption from the land area requirement for provinces composed of one or more islands, as provided in Article 9(2) of the LGC-IRR, should be considered valid. This provision was interpreted as a correction of a legislative oversight in Section 461 of the LGC, which, unlike provisions for municipalities and cities, did not explicitly state this exemption. The Court reasoned that the legislative intent, as evidenced by congressional debates and the formulation of the IRR by an Oversight Committee composed of members from both the Executive and Legislative departments, was to promote local autonomy and development in archipelagic nations. The strict interpretation of the land area requirement would be impractical and counter-productive, especially for island provinces. On the interpretation of the Local Government Code and its Implementing Rules and Regulations: The Court applied the principle that if the literal application of a law results in absurdity or injustice, courts may resort to extrinsic aids like legislative history and implementing rules. The LGC-IRR, formulated by an Oversight Committee with representatives from both houses of Congress, was deemed to reflect both executive and legislative construction of the LGC. The Court found that Congress, by enacting R.A. No. 9355, effectively breathed life into the exemption found in the LGC-IRR, thereby amending the LGC by necessary implication. The Court also highlighted that the land area requirement is not the sole indicator of viability, noting Dinagat's substantial income, which far exceeded the minimum requirement.
Main Doctrine
The Court reconsidered its previous ruling, declared Republic Act No. 9355 (creating the Province of Dinagat Islands) constitutional, and upheld the validity of the exemption from the land area requirement for provinces composed of one or more islands as provided in the Implementing Rules and Regulations of the Local Government Code, considering it as a correction of a legislative oversight and reflective of the intent to promote local autonomy and development in archipelagic nations.