In Aldaba v. Commission on Elections, the Supreme Court of the Philippines addressed the constitutionality of Republic Act No. 9591 (RA 9591), which created a legislative district for Malolos City. The Court ruled that the law was unconstitutional because it failed to meet the population requirements set by Section 5(3), Article VI of the 1987 Constitution, which mandates that cities must have at least 250,000 constituents to be entitled to representation in Congress. This decision reinforces the importance of accurate population data and adherence to constitutional standards in legislative district apportionment, ensuring equitable representation for all citizens.
When Population Counts: Examining the Creation of Legislative Districts
This case revolves around the enactment of RA 9591, which established a separate legislative district for Malolos City. Petitioners Victorino B. Aldaba, Carlo Jolette S. Fajardo, Julio G. Morada, and Minerva Aldaba Morada questioned the law’s constitutionality, arguing that Malolos City did not meet the required population threshold of 250,000 residents. The Commission on Elections (COMELEC), however, contended that the population indicators used by Congress were reliable and that the matter was non-justiciable. This legal battle highlights the critical role of accurate population data in ensuring fair and proportional representation in the legislative branch.
The Supreme Court firmly rejected COMELEC’s argument that the reliability of population data used by Congress is non-justiciable. The Court emphasized its power and duty to review laws creating legislative districts, especially when those laws are challenged for non-compliance with specific constitutional limitations. According to the Court:
To deny the Court the exercise of its judicial review power over RA 9591 is to contend that this Court has no power “to determine whether or not there has been a grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the Government,” a duty mandated under Section 1, Article VIII of the Constitution.
This underscores the judiciary’s role as a check on the legislative branch, ensuring adherence to constitutional mandates. The Court asserted that it cannot simply rubber-stamp laws creating legislative districts without scrutinizing the underlying data supporting their creation. To do so would render the constitutional limitation on population meaningless.
The Court then scrutinized the population indicators relied upon by Congress, particularly the Certification of Alberto N. Miranda (Miranda) from the National Statistics Office (NSO). It found Miranda’s certification unreliable because it did not comply with the requirements of Executive Order No. 135 (EO 135). This EO mandates that population certifications for intercensal years must be based on demographic projections and estimates declared official by the National Statistical and Coordination Board (NSCB), be as of the middle of every year, and be issued by the NSO Administrator or a designated certifying officer.
The Court noted several deficiencies in Miranda’s certification. It was not based on NSCB-approved demographic projections, was not projected as of the middle of 2010, and Miranda was not the NSO Administrator’s designated certifying officer. Moreover, even using Miranda’s growth rate assumption, Malolos City’s population as of August 1, 2010, would still fall below the 250,000 threshold. The Court also dismissed other population indicators presented by COMELEC, such as the 2007 Census of Population – PMS 3 – Progress Enumeration Report, the Certification of the City of Malolos’ Water District, and the Certification of the Liga ng Barangay, as unreliable.
EO 135 excludes certifications from public utilities gathered incidentally and requires local government units conducting their own census during off-census years to seek approval from the NSCB and operate under the technical supervision of the NSO. The Court highlighted the danger of relying on non-NSO authorized certifications, emphasizing the need for stringent standards to ensure the reliability of population data. The Court emphasized that compliance with the population requirement in the creation and conversion of local government units shall be proved exclusively by an NSO certification, as mandated by Section 7 of RA No. 7160.
Unquestionably, representation in Congress is no less important than the creation of local government units in enhancing our democratic institutions, thus both processes should be subject to the same stringent standards.
Aside from population concerns, the Court also found that RA 9591 violated the requirement in Section 5(3), Article VI of the Constitution that each legislative district shall “comprise, as far as practicable, contiguous, compact, and adjacent territory.” The creation of a legislative district for Malolos City isolated the town of Bulacan from the rest of the First Legislative District. The Court suggested that a more appropriate solution would have been to include the municipality of Bulacan in Malolos City’s legislative district to maintain geographic contiguity and compactness.
Ultimately, the Supreme Court denied COMELEC’s motion for reconsideration, reaffirming its decision that RA 9591 was unconstitutional. This ruling underscores the importance of adhering to constitutional requirements for creating legislative districts and ensuring that population data used for such purposes are reliable and authoritative. The Court’s decision serves as a reminder to Congress to exercise caution and diligence when enacting laws that affect the composition of the legislative branch.
FAQs
| What was the key issue in this case? | The key issue was whether Republic Act No. 9591, which created a legislative district for Malolos City, complied with the constitutional requirement that cities must have at least 250,000 residents to be entitled to representation in Congress. |
| What did the Supreme Court rule? | The Supreme Court ruled that RA 9591 was unconstitutional because Malolos City did not meet the population requirement of 250,000 residents, as mandated by Section 5(3), Article VI of the 1987 Constitution. |
| What is Executive Order No. 135 and why is it important? | Executive Order No. 135 sets the standards for population certifications used for official purposes. It is important because it ensures the reliability and authoritativeness of population data used in government decisions, including the creation of legislative districts. |
| Why was the NSO certification deemed unreliable? | The NSO certification was deemed unreliable because it did not comply with the requirements of EO 135, such as being based on NSCB-approved demographic projections and being issued by the NSO Administrator or a designated certifying officer. |
| What does the Constitution say about the contiguity of legislative districts? | Section 5(3), Article VI of the Constitution requires that each legislative district shall “comprise, as far as practicable, contiguous, compact, and adjacent territory.” |
| How did RA 9591 violate the contiguity requirement? | RA 9591 violated the contiguity requirement by creating a legislative district for Malolos City that isolated the town of Bulacan from the rest of the First Legislative District. |
| What is the significance of the population requirement for legislative districts? | The population requirement ensures that each legislative district represents a fair and equitable number of constituents, promoting proportional representation in the legislative branch. |
| What agencies are authorized to conduct population census? | Only the National Statistics Office (NSO) is authorized to conduct population census and local government units with prior approval from the NSCB and under the technical supervision of NSO. |
The Supreme Court’s decision in Aldaba v. COMELEC serves as a crucial reminder of the importance of adhering to constitutional standards in the creation of legislative districts. By invalidating RA 9591, the Court upheld the principle of equitable representation and reinforced the need for accurate and reliable population data in legislative decision-making. This case underscores the judiciary’s role in safeguarding constitutional mandates and ensuring fairness in the political process.
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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: Victorino B. Aldaba, et al. v. COMELEC, G.R. No. 188078, March 15, 2010