Facts:
The province of Bulacan’s representation in the Philippine Congress was divided into four legislative districts, with the first legislative district including the city of Malolos alongside other municipalities. Republic Act No. 9591 (RA 9591), which was passed into law on May 1, 2009, created a separate legislative district solely for Malolos City. The population at the time the legislative bill was filed was 223,069, and projected to reach 254,030 by 2010 based on a certification from the National Statistics Office (NSO). Petitioners, who were taxpayers, registered voters, and residents of Malolos, contested the constitutionality of RA 9591, arguing it did not meet the 250,000 minimum population threshold required for a city to have its legislative district.
The case reached the Supreme Court (SC) after the Solicitor General defended the constitutionality of RA 9591, asserting that Congress’ reliance on population projections was a non-justiciable political question. The petitioners maintained that such projections should not be used as the basis for compliance with constitutional requirements.
Issues:
1. Whether RA 9591, creating a separate legislative district for Malolos City, meets the constitutional population requirement for legislative representation.
2. Whether the use of population projections to create a legislative district is justiciable and constitutional.
Court’s Decision:
The SC decided in favor of the petitioners, declaring RA 9591 unconstitutional. The Court established that the city of Malolos did not meet the required actual or projected population threshold of 250,000 as mandated by the 1987 Constitution, which is a prerequisite for the creation of a legislative district. The NSO’s population projection was deemed unreliable and non-compliant with procedural requirements, such as an absence of official sanctioning by the National Statistics Coordination Board and a proper issuance by the NSO Administrator.
Doctrine:
The Court reaffirmed the doctrine that the population threshold for the creation of a new legislative district in a city, as stipulated in Section 5(3), Article VI of the 1987 Constitution, is a justiciable matter and not merely a political question. Provincial legislative districts must be based on actual or projected population counts that are officially recognized and certified in compliance with established laws and regulations.
Class Notes:
Key Concepts:
– Minimum population requirement for city legislative districts: 250,000 (Section 5(3), Article VI of the 1987 Constitution)
– Nature of population projections used (must be official and certified)
– Justiciability of population requirements in creating legislative districts
Relevant Legal Statutes:
1987 Philippine Constitution, Article VI, Section 5(3): “Each city with a population of at least two hundred fifty thousand, or each province, shall have at least one representative.”
Application Interpreted:
To create a new legislative district, the population count must be at least 250,000. Projections or estimates used must comply with the legal standards and need official recognition. Non-compliance with these standards subjects legislative acts to judicial review.
Historical Background:
The challenge against RA 9591 reflects the ongoing issue of proper representation and adherence to constitutional requirements in the Philippine legislative system. This case underscores the Judiciary’s role in ensuring that the Legislature complies with demographic requisites when creating legislative districts, which significantly impact political representation and governance.
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