Primary Holding

The Supreme Court declared the 16 Cityhood Laws constitutional, concluding that these laws validly amended the Local Government Code by exempting certain municipalities from the new income requirement. The Court held that the legislative intent to exempt these municipalities was clear and that the laws did not violate the equal protection clause or the constitutional provisions regarding the creation of local government units.

Background

The controversy began when Congress passed 16 laws converting municipalities into cities. These laws were challenged on the ground that they did not comply with the requirements of the Local Government Code, particularly the income requirement. The Supreme Court's decisions in these cases have evolved over time, marked by several reversals and shifts in the Court's composition.

Facts

• 1. Congress had enacted 16 Cityhood Laws converting municipalities into cities.
• 2. These municipalities were exempted from the increased income requirement under Republic Act No. 9009, which amended the Local Government Code.
• 3. The petitioners argued that these exemptions violated the Constitution and the Local Government Code.
• 4. The respondents maintained that the laws were constitutional and that the exemptions were valid.

Arguments of the Petitioners

• 1. The petitioners argued that the Cityhood Laws violated the Constitution and the Local Government Code.
• 2. They claimed that the laws did not comply with the requirements for the creation of cities, particularly the income requirement.
• 3. They also argued that the exemptions granted to these municipalities violated the equal protection clause.

Arguments of the Respondents

• 1. The respondents contended that the Cityhood Laws were constitutional.
• 2. They asserted that the laws validly amended the Local Government Code by exempting certain municipalities from the new income requirement.
• 3. They maintained that the legislative intent to exempt these municipalities was clear and that the laws did not violate any constitutional provisions.

Issues

• 1. Whether the Court had jurisdiction to rule on the constitutionality of the Cityhood Laws.
• 2. Whether the Cityhood Laws violated the Constitution and the Local Government Code.
• 3. Whether the exemptions granted to the municipalities violated the equal protection clause.

Ruling

• 1. The Court had jurisdiction to rule on the constitutionality of the Cityhood Laws.
• 2. The Cityhood Laws were constitutional as they validly amended the Local Government Code by exempting certain municipalities from the new income requirement.
• 3. The exemptions did not violate the equal protection clause or any other constitutional provisions.

Doctrines

• 1. Separation of Powers: The Court recognized the principle of separation of powers, acknowledging the role of Congress in enacting laws and the Court's role in reviewing their constitutionality.
• 2. Legislative Intent: The Court emphasized the importance of legislative intent in interpreting statutes.
• 3. Equal Protection Clause: The Court held that the equal protection clause was not violated as the classification of municipalities was based on reasonable and relevant criteria.
• 4. Doctrine of Immutability of Judgments: The Court clarified the application of this doctrine, particularly in cases with multiple motions for reconsideration and evolving decisions.

Key Excerpts

• 1. "We should not ever lose sight of the fact that the 16 cities covered by the Cityhood Laws not only had conversion bills pending during the 11th Congress, but have also complied with the requirements of the LGC prescribed prior to its amendment by R.A. No. 9009."
• 2. "Congress undeniably gave these cities all the considerations that justice and fair play demanded. Hence, this Court should do no less by stamping its imprimatur to the clear and unmistakable legislative intent and by duly recognizing the certain collective wisdom of Congress."

Precedents Cited

• 1. Lambino v. Commission on Elections: Cited in relation to the determination of the issue of constitutionality of the 16 Cityhood Laws.
• 2. Manotok IV v. Heirs of Barque: Cited regarding the Court's disencumbering itself from the shackles of technicality under extraordinary circumstances.
• 3. Province of North Cotabato v. Government of the Republic of the Philippines Peace Panel on Ancestral Domain (GRP): Similar to Manotok IV, this case was cited regarding the Court's approach under extraordinary circumstances.

Statutory and Constitutional Provisions

• 1. Article X, Sections 6 and 10 of the 1987 Constitution: These sections pertain to the creation and alteration of local government units.
• 2. Equal Protection Clause of the Constitution: This clause guarantees equal treatment under the law.
• 3. Republic Acts Nos. 9389, 9390, 9391, 9392, 9393, 9394, 9398, 9404, 9405, 9407, 9408, 9409, 9434, 9435, 9436, and 9491: These are the specific Cityhood Laws in question.
• 4. Republic Act No. 9009: This act amended the Local Government Code, particularly the income requirement for cityhood.
• 5. Local Government Code (Republic Act No. 7160): This code provides the criteria for the creation of local government units.