LEAGUE OF CITIES OF THE PHILIPPINES v. COMELEC (Digested Case)

LEAGUE OF CITIES OF THE PHILIPPINES v. COMELEC

Re: Authority to Create LGUs

FACTS: The 11th Congress enacted into law 33 bills converting 33 municipalities into cities. However, Congress did not act on bills converting 24 other municipalities into cities. In the 12th Congress, RA 9009 was passed ammending Sec. 450 of the LGC by increasing the annual income requirement for conversion of a municipality into a city from P20 to P100 million. After the effectivity of RA 9009, the 12th Congress adopted Joint Resolution No. 29 which sought to exempt from the income requirement the 24 municipalities whose cityhood bills were not approved in the 11th Congress. However, the 12th Congress ended without the Senate approving  Joint Resolution No. 29. In the 13th Congress, the Lower House re-adopted JR 29 as JR 1 which was also not approved by the Senate. Following the advice of Senator Aquilino Pimentel, 16 municipalities filed, through their respective sponsors, individual cityhood bills. The 16 cityhood bills contained a common provision exempting all the 16 municipalities from the P100 million income requirement in RA 9009. These bills were approved by the Congress which later lapsed into law upon the failure of the President to sign the same.

ISSUES:

(1) WON the Cityhood Laws violate Sec. 10, Art. X of the 1987 Constitution.

(2) WON the Cityhood Laws violate the equal protection clause.

HELD:

(1) Yes. First, applying the P100 million income requirement in RA 9009 to the present case is a prospective, not a retroactive application, because RA 9009 took effect in 2001 while the cityhood bills became law more than five years later. Second, the Constitution requires that Congress shall prescribe all the criteria for the creation of a city in the Local Government Code and not in any other law, including the Cityhood Laws. Third, the Cityhood Laws violate Section 6, Article X of the Constitution because they prevent a fair and just distribution of the national taxes to local government units. Fourth, the criteria prescribed in Section 450 of the Local Government Code, as amended by RA 9009, for converting a municipality into a city are clear, plain and unambiguous, needing no resort to any statutory construction. Fifth, the intent of members of the 11th Congress to exempt certain municipalities from the coverage of RA 9009 remained an intent and was never written into Section 450 of the Local Government Code. Sixth, the deliberations of the 11th or 12th Congress on unapproved bills or resolutions are not extrinsic aids in interpreting a law passed in the 13th Congress.

(2) Yes. Even if the exemption in the Cityhood Laws were written in Section 450 of the Local Government Code, the exemption would still be unconstitutional for violation of the equal protection clause, as there is no valid classification to satisfy the equal protection clause.