The Supreme Court’s decision in League of Cities of the Philippines v. COMELEC addresses the constitutionality of cityhood laws that exempted certain municipalities from the increased income requirement for city conversion. The Court ultimately upheld the validity of these laws, asserting that Congress has the power to create political subdivisions and can validly provide exemptions based on reasonable classifications. This ruling clarifies the extent of legislative authority in shaping local governance and sets a precedent for how equal protection principles are applied in the context of local government creation and operation.

From Municipalities to Cities: Can Congress Change the Rules?

The consolidated petitions filed by the League of Cities of the Philippines (LCP) challenged the constitutionality of sixteen cityhood laws, each converting a municipality into a city. These laws exempted the covered municipalities from the PhP 100 million income requirement prescribed by Republic Act No. (RA) 9009, an amendment to the Local Government Code (LGC) of 1991. The LCP argued that these exemptions violated Section 10, Article X of the Constitution, which requires adherence to criteria established in the local government code, and the equal protection clause.

At the heart of the controversy was whether Congress could enact laws that specifically exempted certain municipalities from the uniform income criteria set forth in the LGC. Petitioners argued that the Constitution mandates that all criteria for city creation be written exclusively in the LGC. In contrast, the municipalities contended that Congress retains broad legislative power to create political subdivisions and set the terms for their creation.

The Supreme Court, after initially ruling against the cityhood laws, reconsidered and upheld their validity. The Court emphasized that the power to create political subdivisions is inherently legislative, and the constitutional provision requiring adherence to criteria in the LGC is meant to ensure that Congress, and no other body, sets these criteria. The Constitution’s reference to the LGC does not limit Congress’s ability to enact laws that amend or provide exemptions to the code’s provisions.

Central to the Court’s reasoning was the principle of legislative intent. The Court examined the history surrounding the enactment of RA 9009 and found that Congress did not intend the increased income requirement to apply retroactively to municipalities with pending cityhood bills. This intent was evident in the legislative deliberations, where senators acknowledged the potential unfairness of changing the rules for municipalities that already met the previous income threshold. The cityhood laws, therefore, merely carried out this legislative intent to exempt these municipalities from the stricter income requirement.

The Court also addressed the equal protection challenge, stating that the cityhood laws did not violate the equal protection clause because the exemptions were based on a reasonable classification. The municipalities covered by the cityhood laws were different from other municipalities seeking cityhood because they had pending cityhood bills before RA 9009 took effect and had already met the previous income requirement. This distinction justified the favorable treatment they received under the cityhood laws.

To further clarify its decision, the court used several points to back their decision, stating:

1. That congress did not intend for RA 9009 to apply to the cityhood bills in question
2. That the cityhood laws merely carry out the intent of RA 9009
3. The deliberations of the 11th and 12th congress can be used as extrinsic aids in interpreting a law passed in the 13th congress
4. The exemption accorded the 16 municipalities is based on the fact that they had bills before RA 9009 that substantially distinguish them from other municipalities.

The concept of equal protection requires that all persons or things similarly situated should be treated alike. The Court held that the equal protection clause does not require absolute equality, and the state can recognize and act upon factual differences between individuals and classes. Classification is reasonable if it rests on substantial distinctions, is germane to the purpose of the law, is not limited to existing conditions only, and applies equally to all members of the same class.

Here’s a breakdown of the key arguments and how the court addressed them:

Argument	Court’s Response
Cityhood laws violate Section 10, Article X of the Constitution.	Congress has the power to create political subdivisions, and the provision requiring adherence to criteria in the LGC is meant to ensure that Congress sets those criteria.
Cityhood laws violate the equal protection clause.	The exemptions were based on a reasonable classification. The municipalities covered by the cityhood laws were different from other municipalities seeking cityhood.
The increased income requirement should apply to all municipalities.	Congress did not intend the increased income requirement to apply retroactively to municipalities with pending cityhood bills.

In reaching its decision, the Court also invoked the operative fact doctrine, recognizing that the cities created under the challenged cityhood laws were already functioning with new sets of officials and employees. Upholding the constitutionality of the cityhood laws would avoid disruption and maintain stability in these local government units.

In her dissenting opinion, Justice Carpio disagreed, arguing that Section 7, Rule 56 of the Rules of Court and A.M. No. 99-1-09-SC expressly govern tie-votes and in all incidental matters which include motions for reconsideration, Section 7 of Rule 56 specifically states that if the Court en banc is evenly divided on such matters, the petition or motion shall be denied.

FAQs

What was the key issue in this case?	The central issue was whether cityhood laws exempting certain municipalities from increased income requirements violated the Constitution’s local government code and equal protection clauses.
What did the Supreme Court decide?	The Supreme Court ultimately upheld the validity of the cityhood laws, stating that Congress had the power to create political subdivisions and could grant exemptions based on reasonable classifications.
What is the operative fact doctrine?	The operative fact doctrine recognizes the validity of actions taken under a law before it was declared unconstitutional, particularly when reversing those actions would cause disruption or injustice.
What is the equal protection clause?	The equal protection clause requires that all persons or things similarly situated should be treated alike, both in terms of rights and responsibilities.
What is legislative intent?	Legislative intent refers to the purpose or objective that the legislature sought to achieve when enacting a law, often considered when interpreting ambiguous provisions.
What is the significance of RA 9009?	RA 9009 amended the Local Government Code, increasing the income requirement for municipalities to become cities from PhP 20 million to PhP 100 million.
Why were some municipalities exempted from RA 9009?	Some municipalities were exempted because they had pending cityhood bills before RA 9009 was enacted and had already met the previous income requirement.
What was the vote count?	The Court, voting 6-4, grants the respondent LGUs’ motion for reconsideration of the Resolution of June 2, 2009, as well as their May 14, 2009 motion to consider the second motion for reconsideration of the November 18, 2008 Decision unresolved, and also grants said second motion for reconsideration.

The League of Cities decision provides essential guidance on the balance between legislative power and constitutional limitations in shaping local governance. While Congress has broad authority to create political subdivisions, it must exercise this power reasonably and consistently with equal protection principles. The ruling emphasizes the importance of legislative intent and the need to consider the unique circumstances of local government units when crafting laws that affect their status and operation.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: League of Cities of the Philippines v. COMELEC, G.R. Nos. 176951, 177499, and 178056, December 21, 2009