Primary Holding

The Supreme Court ruled that the initiative petition filed by the Lambino Group was fatally defective because it failed to comply with constitutional requirements. It also reaffirmed the Santiago v. COMELEC ruling that R.A. 6735 is inadequate to implement the people’s initiative to amend the Constitution.

Background

The petitioners, led by Raul Lambino and Erico Aumentado, sought to amend the 1987 Constitution via a people’s initiative by collecting signatures from registered voters. They filed a petition with the COMELEC requesting a plebiscite to ratify their proposed amendments. COMELEC dismissed their petition, citing the Supreme Court’s ruling in Santiago v. COMELEC, which declared R.A. 6735 inadequate to allow an initiative for constitutional amendments. The petitioners then sought recourse with the Supreme Court.

Facts

• 1. The petition sought to amend Articles VI and VII of the 1987 Constitution, changing the structure of government from a Bicameral-Presidential system to a Unicameral-Parliamentary system.
• 2. The petitioners alleged that they gathered 6.3 million signatures, meeting the constitutional threshold of at least 12% of total registered voters, with at least 3% in each legislative district.
• 3. The petitioners claimed that COMELEC election registrars had verified these signatures.
• 4. COMELEC dismissed the petition for lack of an enabling law, citing Santiago v. COMELEC.

Arguments of the Petitioners

• 1. The initiative petition complied with the numerical requirements set in Section 2, Article XVII of the Constitution.
• 2. The COMELEC’s reliance on Santiago v. COMELEC was misplaced because that case’s ruling was not binding on them.
• 3. The will of the people must be upheld as their initiative represents direct democracy.
• 4. COMELEC committed grave abuse of discretion in denying due course to the petition.

Arguments of the Respondents

• 1. The initiative was invalid because it was not directly proposed by the people, as the full text of the amendments was not included in the petition signed by the people.
• 2. The proposed changes constituted a revision, not a mere amendment, which is outside the scope of a people’s initiative.
• 3. The Supreme Court had already ruled in Santiago v. COMELEC that R.A. 6735 was inadequate to implement a people’s initiative for constitutional amendments.
• 4. The petition was a veiled attempt at logrolling, containing multiple unrelated constitutional changes.

Issues

• 1. Did the initiative petition comply with the constitutional requirement that amendments must be "directly proposed by the people"?
• 2. Should the Supreme Court revisit its ruling in Santiago v. COMELEC, which declared R.A. 6735 inadequate to implement a people’s initiative for constitutional amendments?
• 3. Did the COMELEC commit grave abuse of discretion in denying the petition?

Ruling

• 1. The Supreme Court ruled against the petitioners
• 2. The petition did not comply with the requirement that amendments be "directly proposed by the people through initiative upon a petition," as the full text of the proposed amendments was not attached to the signature sheets.
• 3. The initiative was a revision rather than a mere amendment, which is not allowed under the people’s initiative mode.
• 4. The Court reaffirmed Santiago v. COMELEC, maintaining that R.A. 6735 was inadequate for initiatives proposing constitutional amendments.
• 5. The COMELEC did not commit grave abuse of discretion in dismissing the petition.

Doctrines

• 1. Doctrine of Direct Proposal: People’s initiative requires the full text of the amendment to be presented to voters before signing.
• 2. Doctrine of Amendment vs. Revision: People’s initiative can only propose amendments, not revisions. A revision involves fundamental structural changes.
• 3. Doctrine of Judicial Precedent: Santiago v. COMELEC remains binding and prevents COMELEC from entertaining people’s initiatives for constitutional amendments under R.A. 6735.

Precedents Cited

• 1. Santiago v. COMELEC – Declared R.A. 6735 inadequate to implement constitutional amendments via initiative.
• 2. McFadden v. Jordan – Distinguished constitutional amendments from revisions.
• 3. Adams v. Gunter – Ruled that a shift from bicameral to unicameral legislature constitutes a revision, not an amendment.

Statutory and Constitutional Provisions

• 1. 1987 Constitution: Article XVII, Section 2 – People’s initiative requirements
• 2. 1987 Constitution: Article VI and VII – Structure of government
• 3. R.A. 6735 (Initiative and Referendum Act) – Found inadequate to implement constitutional amendments