Facts:
The petitioners assailed the constitutionality of Republic Act No. 11259, which aims to divide the Province of Palawan into three new provinces: Palawan del Norte, Palawan Oriental, and Palawan del Sur. House Bills No. 7413 and 8055, initiated the legislative process and were passed by the 17th Congress, signed into law on April 5, 2019, and published on May 20, 2019.
Key provisions of RA 11259 are:
– Section 51 mandates a plebiscite for approval by the voters from affected areas on the second Monday of May 2020.
– Section 54 disallows residents of the highly urbanized City of Puerto Princesa from voting in the plebiscite and in provincial elections.
Petitioners consist of residents from Puerto Princesa and other municipalities in Palawan, who, claiming standing as taxpayers and voters, sought the Supreme Court to declare RA 11259 unconstitutional and enjoin the upcoming plebiscite. They based their petition on three core issues:
1. Lack of public hearings and consultations for the law’s passage.
2. Disenfranchisement of Puerto Princesa voters from the plebiscite.
3. Alteration of natural resource revenue sharing among the new provinces and existing municipalities and barangays.
The respondents included the Commission on Elections, Department of Budget and Management, Provincial Government of Palawan, and its Provincial Treasurer, who argued that proper consultation with local government representatives occurred, and that the plebiscite would serve as the highest form of public consultation.
Issues:
1. Whether the petitioners have legal standing to challenge RA 11259.
2. Whether prior public consultation is required for the law’s validity.
3. Whether Puerto Princesa residents should participate in the plebiscite for the division of Palawan.
4. Whether the provision of natural resource revenue sharing violates the constitution.
Court’s Decision:
1. **Standing**:
– The Court ruled that the Puerto Princesa petitioners lack standing since Puerto Princesa, as an HUC, is independent of Palawan. However, petitioners from other parts of Palawan have standing as the law directly affects them.
2. **Prematurity of Petition**:
– The law’s effect is contingent upon the plebiscite approval, and issues must involve actual implementation rather than preemptive invalidation. Hence, the petition was deemed premature concerning any provisions related to the newly created provinces.
3. **Public Consultations**:
– The court upheld that while public consultation is a valued democratic process, the Constitution did not explicitly require public consultations for law passage. The legislative process included engagement with local government officials and overall public consultation through the plebiscite. Therefore, consultations held through provincial representatives were enough.
4. **Participation in Plebiscite**:
– The Court determined Puerto Princesa, as an HUC, is not a political unit directly affected by the province’s division. Voters of HUCs are excluded from participating in provincial elections per the Local Government Code (Sec. 452) and Constitution (Art. X, Sec. 12). The political and economic consequences of becoming an HUC rendered Puerto Princesa autonomous from Palawan, thus justifying their non-participation in the plebiscite.
Doctrine:
The ruling reinforces the principle that highly urbanized cities (HUCs) are independent of their host provinces, reflecting the intention to provide greater local autonomy. Exclusions from provincial elections and plebiscites concerning changes in provincial structures reiterate this statutory and constitutional interpretation.
Class Notes:
– **Standing to Sue**: Requires a substantial interest and actual or threatened injury directly resulting from the challenged governmental act.
– **Public Consultation**: Though desirable, explicit prior public consultation is not constitutionally required for legislative validity.
– **HUC Independence**: Based on Section 452 of the Local Government Code and Article X, Section 12 of the Constitution, HUCs function autonomously and do not participate in provincial elections.
– **Plebiscite and Directly Affected Units**: A city’s control, fiscal independence, and self-governing functions exclude it from provincial plebiscites.
Historical Background:
The case forms part of the Philippines’ ongoing search for local governance reforms that balance autonomy and administrative efficiency. The distinction between component cities and highly urbanized cities (HUCs) seeks to promote self-sufficiency while decentralizing administrative duties from provincial oversight. This decision clarifies legal interpretations in the evolving context of local government autonomy and the role of plebiscites in democratic participation.
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