Almario v. Alba
REITERATIONFacts
The Antecedents: The case concerns proposed amendments to the Philippine Constitution, specifically Resolution Nos. 105 and 113, which were to be submitted to the electorate for ratification or rejection on January 27, 1984. Resolution No. 105 proposed to amend Sections 11 and 12 of Article XIV, primarily by adding the word "grant" as an additional mode for the acquisition of public lands and expanding the agrarian reform program. Resolution No. 113 proposed to add a paragraph to Section 12 of Article XIV, establishing an urban land reform and social housing program. Procedural History: The petitioners, Alex G. Almario and others, filed a petition seeking to enjoin the submission of Questions Nos. 3 and 4 (corresponding to Resolution Nos. 105 and 113) to the people. They argued that there had not been a fair and proper submission of these amendments, preventing the electorate from making an intelligent appraisal of their meaning and implications. The case was heard by the Supreme Court, which subsequently issued a resolution dismissing the petition. The Petition: The petitioners sought a prohibition with preliminary injunction to stop the plebiscite for Questions Nos. 3 and 4, arguing that the submission of these constitutional amendments was not fair and proper, citing the doctrine from Tolentino v. COMELEC. They contended that the electorate had insufficient time and basis for an intelligent appraisal of the amendments' nature and relation to existing constitutional provisions. The Supreme Court, however, found that the petitioners failed to demonstrate that the average voter could not understand the proposed amendments and that the periods provided for information campaigns were sufficient, leading to the dismissal of the petition for lack of merit.
Issue(s)
Whether the submission of constitutional amendments under Question Nos. 3 and 4 was fair and proper, providing the electorate with sufficient time and basis for an intelligent appraisal. Whether the proposed amendments, concerning the 'grant' of public lands and 'urban land reform,' were of such a nature that the people could not arrive at an intelligent judgment.
Ruling
The Court Resolved to DISMISS the petition for lack of merit.
Ratio Decidendi
On the fairness and propriety of the submission: The Court found that the petitioners failed to show that the amendments were not fairly and properly submitted. The Constitution allows a period of not more than three months for information campaigns, and the sufficiency of this period depends on the complexity of the questions. The Court determined that the addition of the word 'grant' to Article XIV, Section 11, or the addition of paragraphs on urban land reform to Article XIV, Section 12, did not render the amendments so complex as to prevent an intelligent judgment from the electorate. The Court noted that existing constitutional provisions already supported programs for the grant of public lands and urban land reform, and that the proposed amendments would serve at most a symbolic purpose, confirming existing practices or providing a clearer constitutional basis. The Court found the periods provided for information campaigns (67 days for Resolution No. 105 and 42 days for Resolution No. 113) to be sufficient, especially when compared to historical precedents where amendments were submitted for shorter periods. The Court cited Sanidad v. Commission on Elections regarding the sufficiency of submission periods. The Court also noted that the proposed amendments were relatively simple and easy to comprehend compared to other amendments being submitted, and that the wisdom of these proposals was a matter for the people to decide through their votes, not for the Court to substitute its own aversion. On the electorate's understanding of the amendments: The Court held that the necessity, expediency, and wisdom of the proposed amendments were beyond the courts' power to adjudicate. The issue was whether the voters were aware of the wisdom, desirability, or dangers of abuse, not whether the amendments themselves were wise or desirable. The Court found that the petitioners failed to demonstrate that the average voter did not understand the meaning of 'grant' of public land or 'urban land reform,' citing the long-standing public consciousness of agrarian reform and land disposition laws, as well as urban housing programs. The Court also pointed to the publication of amendments, discussions in various forums, and the assurances of the Commission on Elections (COMELEC) regarding information dissemination.
Main Doctrine
The Supreme Court dismissed a petition seeking to enjoin the submission of certain constitutional amendments to a plebiscite, holding that the petitioners failed to show that the amendments were not fairly and properly submitted to the electorate, and that the wisdom of the amendments is a matter for the people to decide.