Primary Holding
The Supreme Court upheld the constitutionality of Republic Act No. 4913 and the congressional resolutions proposing the amendments, ruling that submission during a general election complied with Article XV. However, six justices in concurring opinions found the public’s awareness insufficient for valid ratification.
Background
Congress passed Resolutions 1 and 3 (proposing amendments) and Resolution 2 (calling a future constitutional convention) on March 16, 1967. RA 4913 scheduled the plebiscite during the 1967 general election. Petitioners argued the amendments were rushed and inadequately publicized.
History
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March 16, 1967: Congress adopts Resolutions 1, 2, and 3.
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June 17, 1967: RA 4913 (plebiscite law) takes effect.
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October 21, 1967: Gonzales files G.R. No. L-28196.
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October 31, 1967: PHILCONSA files G.R. No. L-28224.
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November 8, 1967: Cases consolidated and submitted for decision.
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November 9, 1967: Supreme Court issues judgment.
Facts
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1.
Congress proposed amendments to increase House representatives from 120 to 180 and allow legislators to join a constitutional convention without forfeiting seats. RA 4913 set the plebiscite alongside the 1967 general elections, with amendments printed on ballot backs and minimal public education efforts.
Arguments of the Petitioners
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1.
RA 4913 violated Article XV by using a general election instead of a special plebiscite.
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2.
Congress was a de facto body due to failure to reapportion districts post-1960 census.
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3.
The amendments were not sufficiently publicized, violating due process.
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4.
Congress could not simultaneously propose amendments and call a convention.
Arguments of the Respondents
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1.
The Constitution permits ratification during general elections.
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2.
Congress remained de jure despite apportionment delays.
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3.
RA 4913’s publication and ballot printing complied with legal standards.
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4.
Political questions (e.g., Congress’s status) were non-justiciable.
Issues
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1.
Does the Court have jurisdiction over constitutional amendment challenges?
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2.
Was Congress a de facto body due to reapportionment failure?
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3.
Could amendments be ratified during a general election?
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4.
Did RA 4913 ensure adequate public awareness for valid ratification?
Ruling
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1.
Jurisdiction: The Court affirmed its authority to review constitutional amendments.
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2.
Congress’s Legitimacy: Congress was de jure; apportionment delays did not invalidate its acts.
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3.
General Election Validity: Article XV permits ratification during general elections.
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4.
Public Awareness: The majority found RA 4913’s measures sufficient, but concurring justices criticized the lack of voter education.
Doctrines
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1.
Judicial Review of Amendments: Courts may review procedural compliance with constitutional amendment requirements.
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2.
De Facto Officer Doctrine: Officials’ acts remain valid even if their title is later contested.
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3.
Non-Delegation Principle: Congress’s power to propose amendments is non-delegable.
Key Excerpts
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1.
“The judicial department is the only constitutional organ which can be called upon to determine the proper allocation of powers between the several departments.”
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2.
“A constitutional amendment is not a temporary expedient… it is an expression of the people’s sovereign will.” (Concurring opinion)
Precedents Cited
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1.
Mabanag v. Lopez Vito (1947): Initially deemed amendments a political question but weakened by later rulings.
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2.
Macias v. COMELEC (1961): Struck down invalid apportionment, cited on Congress’s duties.
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3.
Angara v. Electoral Commission (1936): Established judicial review over constitutional disputes.
Statutory and Constitutional Provisions
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1.
Article XV, Section 1: Procedure for constitutional amendments.
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2.
Article VI, Section 5: Congressional apportionment rules.
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3.
Republic Act No. 4913: Law implementing the plebiscite.