Facts:
In 2006, petitioners Raul L. Lambino and Erico B. Aumentado, representing themselves and 6,327,952 registered voters, initiated a signature campaign for a people’s initiative to amend the 1987 Philippine Constitution. The aim was to change the government system from bicameral-presidential to unicameral-parliamentary. They gathered signatures and submitted a petition to the Commission on Elections (COMELEC) to hold a plebiscite for ratifying the initiative as provided under Section 5(b) and (c) and Section 7 of Republic Act No. 6735 (The Initiative and Referendum Act).
The COMELEC denied the petition, invoking the Supreme Court’s ruling in Santiago vs. COMELEC which declared RA 6735 inadequate for constitutional amendments through initiatives. Lambino Group argued that COMELEC committed grave abuse of discretion in denying the petition. They contended that Santiago is neither a binding precedent nor does it apply to their case since they believe their petition truly expressed the will of the sovereign people.
Intervenors in the case included groups opposing and supporting the initiative, raising various legal contentions. The Court held oral arguments and subsequently received memoranda from the parties.
Issues:
1. Whether the Lambino Group’s initiative complied with Section 2, Article XVII of the Constitution regarding direct proposal by the people.
2. Whether the Supreme Court should revisit its ruling in Santiago v. COMELEC which declared RA 6735 inadequate for constitutional initiatives.
3. Whether the COMELEC committed grave abuse of discretion in denying the Lambino Group’s petition.
Court’s Decision:
The Supreme Court found no merit in the Lambino Group’s petition, stating that it failed to comply with the basic requirements of the Constitution for conducting a people’s initiative. Therefore, there was no need to revisit the Santiago ruling. The initiative petition did not comply with Section 2, Article XVII of the Constitution since the full text of the proposed amendments was neither shown to nor signed by the people as required. The Lambino Group’s initiative was also deemed a revision, not merely an amendment, thereby exceeding the scope of what is allowed under the framework for constitutional change through a people’s initiative.
Doctrine:
The Supreme Court upheld the principle that any proposal to amend the Constitution through a people’s initiative must (1) be put into writing and signed by the petitioners and (2) comply with the percentage requirement of registered voters’ signatures. The Court reiterated the doctrine that a people’s initiative can only propose amendments, not revisions, to the Constitution.
Class Notes:
– A constitutional amendment differs from a revision. An amendment generally affects a specific article or provision, while a revision impacts several articles or alters the basic governmental plan.
– For a people’s initiative to be valid:
– The full text of the proposed amendment must be shown to the people before they sign the petition.
– It must comply with the number of required signatures as prescribed by the Constitution.
– It must propose only amendments, not revisions, to the Constitution.
– The Supreme Court’s earlier ruling in Santiago v. COMELEC remains guiding law until otherwise overturned by the Court or superseded by subsequent legislation.
– Grave abuse of discretion by a government agency involves capricious and whimsical exercise of judgment as is equivalent to lack of jurisdiction. The mere abuse of discretion is not enough and must be grave, as when the power is exercised in an arbitrary or despotic manner by reason of passion or personal hostility.
Historical Background:
The case is set against the backdrop of perennial debates on charter change (‘cha-cha’) in the Philippines. Since the 1987 Constitution’s ratification, various administrations have attempted to amend or revise the Constitution either to shift to a parliamentary system, introduce economic reforms, or lift term limits of public officials. The Lambino Group’s initiative mirrored these efforts, reflecting an ongoing political and societal discourse on the most suitable governmental system for the Philippines. The case once more emphasized the procedural rigors for constitutional change, implying the need for deliberate and careful consideration when altering the nation’s fundamental law.
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