**Gemiliano C. Lopez, Jr. vs. The Commission on Elections and Metropolitan Manila Commission**
### Facts
The case involves a challenge to the constitutionality of Presidential Decree No. 824 (PD 824), which was enacted in response to the escalating demands for a centralized government for the management of Metropolitan Manila, encompassing Manila, Quezon, Pasay, Caloocan, and 13 surrounding municipalities. The decree established the Metropolitan Manila as a public corporation, administered by a Commission, with wide-ranging powers similar to a corporate entity.
The petitioners, Gemiliano C. Lopez, Jr. (an Assemblyman of Metropolitan Manila) and Reynaldo B. Aralar, representing interested parties in Metropolitan Manila, questioned PD 824’s validity on the ground that it violated a constitutional provision requiring local government reorganization to be subject to criteria established in the Local Government Code and approval through a plebiscite. The assertion was that the decree was enacted before the Local Government Code of 1983 came into existence and thus failed to observe constitutional procedural requirements.
The progression to the Supreme Court involved the petitioners questioning both the constitutionality of PD 824 and pressing for elections for members of the Sangguniang Panglungsod and Sangguniang Bayan in Metropolitan Manila per existing laws governing local governments, highlighting a suite of procedural and constitutional issues.
### Issues
The main issues resolved by the Supreme Court were:
1. Whether Presidential Decree No. 824 violated the constitutional provision requiring changes to local government units to comply with the criteria established in the Local Government Code and be subject to a plebiscite.
2. Whether the absence of elections for the Sangguniang Panglungsod and Sangguniang Bayan in the Metropolitan Manila area constituted a violation of the constitutional guarantee of equal protection.
3. The extent of the President’s control over the Metropolitan Manila Commission and the constitutional validity thereof.
### Court’s Decision
The Supreme Court dismissed the petitions, upholding the constitutionality of PD 824. The Court reasoned that a plebiscite held on February 27, 1975, satisfied the constitutional requirement for public consent to the restructuring of local governments within Greater Manila. It further noted that the authority to issue PD 824 stemmed from the President’s legislative powers during the period of martial law.
On equal protection issues related to the absence of local elections, the Court found no violation, holding that the unique structure and governance needs of Metropolitan Manila justified a different mechanism for representation and government.
Regarding the President’s control over the Metropolitan Manila Commission, the Court determined it does not infringe upon the constitutional provisions since the decree aligns with national administrative goals and the President is deemed to have supervisory authority rather than absolute control over local government units.
### Doctrine
The case restates the doctrine that laws are presumed constitutional, and challenges must present a clear and unequivocal breach of the Constitution to succeed. It also underlines the principle that the equal protection clause permits reasonable classification based on substantial differences relevant to legitimate government objectives.
### Class Notes
– **Presumption of Constitutionality:** Legal challenges must demonstrate a clear violation of the Constitution.
– **Equal Protection Clause:** Allows reasonable classification if it is based on substantial differences with a legitimate state objective.
– **Presidential Powers:** During martial law or extraordinary circumstances, the President may exercise broader powers, including legislative functions, subject to constitutional limits.
– **Local Government Reorganization:** Changes to local government structures are subject to criteria established in the applicable legal code and require public approval via a plebiscite.
### Historical Background
PD 824 was part of broader administrative reforms in the Philippines, aimed at addressing the challenges of urbanization and governance in the rapidly growing Metropolitan Manila area. The assertion of its constitutionality by the Supreme Court emphasizes the judiciary’s deference to legislative and executive decisions made in response to pressing social and administrative needs, within the bounds of the Constitution.
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