G.R. No. 189793. April 07, 2010 (Case Brief / Digest)

### Title: Senator Benigno Simeon C. Aquino III and Mayor Jesse Robredo vs. Commission on Elections

### Facts:
In the case of Senator Benigno Simeon C. Aquino III and Mayor Jesse Robredo vs. Commission on Elections (COMELEC), the facts are as follows:

1. **Legislation Background:**
– Republic Act No. 9716, which originated from House Bill No. 4264, was signed into law by President Gloria Macapagal Arroyo on October 12, 2009.
– The law created a new legislative district for the Province of Camarines Sur by reconfiguring its first and second legislative districts.

2. **Reconfiguration Details:**
– Before Republic Act No. 9716, Camarines Sur’s population of 1,693,821 was distributed across four legislative districts.
– The reconfiguration transferred several municipalities between districts to create a new, fifth district. This resulted in the revisit of population distribution as follows:
– **1st District:** 176,383
– **2nd District:** 276,777
– **3rd District:** 439,043
– **4th District:** 372,548
– **5th District:** 429,070

3. **Petitioners’ Argument:**
– Senator Aquino and Mayor Robredo argued that the reapportionment violates Section 5(3), Article VI of the 1987 Constitution, which requires a minimum population of 250,000 for creating a legislative district.
– The newly apportioned first district only has a population of 176,383, which does not meet the said requirement.

4. **Respondent’s Argument:**
– COMELEC, through the Office of the Solicitor General, contended that the 250,000 population requirement only applies to cities, not provinces.

5. **Procedural Posture:**
– Petitioners filed a Petition for Certiorari and Prohibition under Rule 65 of the Rules of Court, challenging the constitutionality of Republic Act No. 9716 and seeking to restrain COMELEC from implementing it.

### Issues:
The Supreme Court was tasked to resolve the following legal issues:

1. **Whether the 250,000 minimum population requirement set forth in Section 5(3), Article VI of the 1987 Constitution applies to the creation of legislative districts in provinces.**
2. **Whether the petitioners have the legal standing and chose the correct legal remedy.**

### Court’s Decision:
The Supreme Court’s detailed ruling resolved these legal issues as follows:

1. **On the Population Requirement:**
– The Court found no specific constitutional provision fixing a 250,000 minimum population for legislative districts in provinces.
– The distinction drawn in Section 5(3), Article VI of the Constitution indicates that while cities must have at least 250,000 people to create a legislative district, this requirement does not apply to provinces.
– The Court upheld the interpretation that provinces are entitled to at least one representative regardless of population size but added new districts depending on other factors such as geographical contiguity and community interest.
– Thus, Republic Act No. 9716 did not violate the Constitution by creating a legislative district with a population below 250,000.

2. **On Procedural and Standing Issues:**
– Despite procedural challenges raised by respondents, the Court opted to address the substantive issues due to the transcendental importance of the matter.
– The Court has consistently allowed deviation from strict procedural rules when there are issues of paramount public importance. Hence, the petitioner’s legal standing and choice of remedy (Certiorari and Prohibition) were accepted.

### Doctrine:
The primary doctrine established/reiterated by this decision includes:

– **Distinct Population Requirements for Cities vs. Provinces:** The 250,000 minimum population requirement explicitly applies to creating legislative districts for cities, **not** for provinces.
– **Paramount Public Interest and Procedural Deviation:** When a case involves transcendental public importance, the Supreme Court may relax procedural rules and requirements for locus standi.

### Class Notes:
**Key Elements/Concepts:**

– **Constitutional Provision Interpretation:** Differentiation between cities and provinces in district creation.
– **Relaxed Procedural Rules:** Courts can waive procedural technicalities in cases of significant public interest.

**Key Statutes:**

– **1987 Constitution, Article VI, Section 5(3):** “Each legislative district shall comprise, as far as practicable, contiguous, compact, and adjacent territory. Each city with a population of at least two hundred fifty thousand, or each province, shall have at least one representative.”
– **Local Government Code:** Provides guidelines on the creation of new provinces, specifying requirements like income and population.

### Historical Background:
Republic Act No. 9716 and the issues arising from its enactment can be seen in the context of political maneuvering and legislative reapportionment, which are often fraught with debates over fairness, representation, and adherence to constitutional mandates. The insistence on addressing these through the judiciary reflects the constitutional checks and balances designed to prevent gerrymandering and preserve the principles of representative democracy. The decision underscores ongoing tensions between legislative prerogatives and constitutional constraints in the evolving Philippine political landscape.


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