**Facts:**
1. On July 11, 2011, the Sangguniang Panglungsod of Cabanatuan City passed Resolution No. 183-2011, requesting the President to declare Cabanatuan City as a highly urbanized city (HUC).
2. The President issued Presidential Proclamation No. 418, Series of 2012, on July 11, 2012, proclaiming Cabanatuan City as an HUC pending the results of a plebiscite mandated by Section 453 of the Local Government Code of 1991 (LGC).
3. On September 11, 2012, the COMELEC issued Minute Resolution No. 12-0797, stating that only residents of Cabanatuan City shall participate in the plebiscite.
4. Governor Aurelio M. Umali of Nueva Ecija filed a Motion for Reconsideration, asserting that Section 453 should be read in conjunction with Section 10, Article X of the Constitution, which mandates plebiscite approval by voters in the LGUs directly affected.
5. COMELEC denied the motion on October 16, 2012, and issued Minute Resolution No.12-0925, maintaining that only Cabanatuan City residents could vote.
6. Aurelio Umali then filed a Petition for Certiorari and Prohibition (G.R. No. 203974) with prayer for injunctive relief to the Supreme Court, contesting the COMELEC resolutions.
7. Petitioner J.V. Bautista filed a Petition for Mandamus (G.R. No. 204371) seeking the immediate scheduling of the plebiscite upon expiration of the RTC’s TRO, given that it should be held within 120 days from the President’s declaration.
8. Both petitions were consolidated. During litigation, COMELEC rescheduled the plebiscite multiple times and finally postponed it post-May 2013 elections.
**Issues:**
1. Whether the plebiscite for Cabanatuan City’s conversion to an HUC should include the entire province of Nueva Ecija or just Cabanatuan City.
2. Should the COMELEC resolutions limiting the plebiscite to Cabanatuan City residents be declared null and void?
3. Is the Mandamus petition filed by J.V. Bautista to enforce the plebiscite scheduling meritorious?
**Court’s Decision:**
1. **Interpretation of Sec. 453 of the LGC in line with Sec. 10, Art. X of the Constitution**:
– The Supreme Court ruled that the phrase “political units directly affected” in Sec. 10, Art. X of the Constitution must guide the interpretation of Sec. 453 of the LGC.
– The constitutional provision prevails, requiring the participation of all direct political units affected, encompassing provincial voter inclusion in decisions potentially altering economic and political structures.
– Conversion into an HUC equates to substantial boundary alteration impacting both the city and province.
2. **Invalidity of COMELEC’s resolutions**:
– Minute Resolutions No. 12-0797 and No. 12-0925 were declared null and void for contradicting constitutional stipulations.
3. **Necessity of broader electoral participation**:
– The plebiscite must engage voters both from Cabanatuan City and the entire Nueva Ecija province, considering the substantial effects on provincial political oversight and economic resource allocation (i.e., diminutions in IRA shares, tax revenues, and administrative jurisdiction).
4. **Doctrine**:
– The Court held that statutory provisions must be interpreted harmoniously, ensuring alignment with constitutional mandates.
– Substantial boundary alterations necessitate wider elective participatory processes to reflect the plebiscite’s comprehensive impact.
**Doctrine:**
1. Constitutional Supremacy: Statutes must conform to constitutional mandates.
2. Direct Political Units Affected: Plebiscites for changes in political status must include voters from all significantly impacted political units.
**Class Notes:**
1. **Elements of Plebiscite Requirement**:
– LGU status changes (e.g., creation, merger, or conversion) require approval from all directly affected voters.
– Relevant statutes: Section 453 of LGC; Section 10, Article X of the 1987 Constitution.
2. **Statutory Interpretation**:
– Harmonize statutes with constitutional directives to uphold rights of all affected political entities.
3. **Conversion to HUC**:
– Affects administrative oversight, tax revenues, IRA sharing, and electors’ voting rights.
**Historical Background:**
1. The case reflects ongoing legal discourse on local autonomy in the Philippines.
2. This decision underscores the judiciary’s role in balancing local government code provisions with overarching constitutional principles to protect comprehensive democratic processes.
3. The Cabanatuan City case aligns with broader trends of strengthening LGU systemic checks to enforce equitable administrative growth and political representation in evolving urban centers.
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