Macalintal vs. The Senate of the Philippines

A law that primarily sets the term of office of barangay officials pursuant to Article X, Section 8 of the Constitution is a term-setting law, not an election postponement law, and is therefore not subject to the Macalintal guidelines—even if it incidentally results in the deferment of a previously scheduled election—provided its central and animating purpose is establishing a new term structure for barangay and Sangguniang Kabataan officials.

Republic Act No. 12232, signed by President Ferdinand R. Marcos Jr. on August 13, 2025, is titled "An Act Setting the Term of Office of Barangay Officials and Members of the Sangguniang Kabataan, and for Other Purposes." It sets a four-year term for elected barangay and SK officials, schedules the next BSKE on the first Monday of November 2026 and every four years thereafter, fixes the assumption of office on the first day of December following election, and provides for a hold-over of incumbent officials until their successors are elected and qualified. The law operates against the backdrop of Macalintal vs. Commission on Elections (2023), where the Court declared Republic Act No. 11935 unconstitutional for postponing the December 2022 BSKE without sufficient justification, and laid down five-point criteria for evaluating future election postponement laws. Following Macalintal, Republic Act No. 11462—which set the next BSKE on the first Monday of December 2025—remained the controlling statute. Multiple petitioners, acting as voters, taxpayers, lawyers, and youth-sector members, filed separate petitions challenging RA 12232 or portions thereof, which were consolidated. The Liga ng mga Barangay sa Pilipinas and several punong barangays sought to intervene in opposition to the Macalintal petition.

On August 13, 2025, President Ferdinand R. Marcos Jr. signed Republic Act No. 12232, entitled "An Act Setting the Term of Office of Barangay Officials and Members of the Sangguniang Kabataan, and for Other Purposes." The law's salient features include: a four-year term of office for all elected barangay and Sangguniang Kabataan officials, with a three-consecutive-term limit for barangay officials and a single-term limit for SK officials; the scheduling of the next regular BSKE on the first Monday of November 2026 and every four years thereafter; the commencement of the term of office on the first day of December following election; and a hold-over provision allowing all incumbent BSK officials to remain in office unless sooner removed or suspended for cause until their successors have been elected and qualified. A transitory provision disqualifies incumbent elective barangay officials serving their third consecutive term from running for the same position in the November 2026 BSKE.

Two days after the law's enactment, on August 15, 2025, Romulo B. Macalintal, a registered voter, taxpayer, and practicing lawyer, filed a Petition for Certiorari and Prohibition impleading the Senate, the House of Representatives, the Office of the President, and the COMELEC, seeking to declare RA 12232 unconstitutional or at least the portions pertaining to the postponement of the December 2025 BSKE. On the same day, John Barry T. Tayam, a citizen, taxpayer, registered voter, educator, and youth-sector member, filed a separate petition impleading the COMELEC, President Marcos Jr., the Senate President, and the Speaker of the House, likewise seeking to declare the law unconstitutional. Thereafter, on August 22, 2025, Mystro Yushi P. Fujii and four other registered voters filed their petition challenging Sections 2, 3, and 4 of RA 12232, while on September 3, 2025, Atty. Alberto N. Hidalgo and others representing Youth for Transformative Leadership Movement filed a petition challenging Sections 2 and 4.

On August 26, 2025, the Liga ng mga Barangay sa Pilipinas and several punong barangays filed a Petition-In-Intervention with Opposition, seeking to intervene in G.R. No. E-02002 and praying for the dismissal of the Macalintal Petition. They claimed to represent the interests of their member-barangays, asserting that if RA 12232 were declared unconstitutional, the December 2025 BSKE would push through and the barangay officials elected during the October 2023 BSKE would serve only two years instead of three. The OSG filed its Consolidated Comment on September 9, 2025, defending the law as a valid term-setting measure and praying for denial of the petitions. On October 6, 2025, Macalintal filed an Urgent Omnibus Motion for Early Resolution in view of supervening events, including the postponement of the October 13, 2025 BARMM elections and COMELEC's termination of its preparations for the 2025 BSKE. The Court consolidated all four petitions and resolved the Petition-In-Intervention and the substantive constitutional questions together.

• Macalintal Guidelines: Petitioner Macalintal argued that RA 12232 violates the guidelines set in Macalintal vs. COMELEC because it postpones the December 2025 BSKE without any legitimate government interest or objective.
• Retroactive Application: Macalintal maintained that RA 12232 retroactively applies its term-lengthening provision to incumbent BSK officials in violation of the citizenry's right to suffrage and the equal protection clause.
• One Subject-One Title: Macalintal contended that the law violates the "one subject-one title" rule under Article VI, Section 26(1) of the Constitution since the postponement of the December 2025 BSKE and the extension of the tenure of incumbent BSK officials are inconsistent or foreign to the general subject of the law.
• Right to Suffrage: Tayam argued that the law violates the citizenry's right to vote, and the postponement lacks legitimate government interest or compelling reasons such as a public emergency, undermining the people's right to suffrage contrary to the Macalintal guidelines.
• Democratic Government: Tayam maintained that the law's postponement of the BSKE and extension of incumbent terms violates the essence of a democratic government, which relies on genuine and periodic elections.
• Equal Protection — SK Officials: Tayam argued that the law violates the equal protection clause by limiting SK officials to a single term, creating disparate treatment between different classes of local officials and unfairly affecting SK candidates who would exceed the maximum age of 24 by the rescheduled election date.
• Disenfranchisement of Youth: Tayam contended that the postponement from December 2025 to November 2026 disenfranchises a specific demographic of youth who are 24 years old on December 1, 2025 and still eligible to file certificates of candidacy, but who will be ineligible for the November 2026 BSKE because they will turn 25 in the interim.
• Term vs. Tenure Distinction: Fujii et al. argued that the retroactive application of the term-lengthening provision is merely an attempt to postpone the December 2025 BSKE and circumvent the ruling in Macalintal. They asserted that the distinction between "term" and "tenure" discussed in Macalintal is a mere legal fiction that allows the unconstitutional extension of term of BSK officials, and that the hold-over doctrine defeats the people's right to periodic elections.
• Riders: Fujii et al. and Hidalgo et al. claimed that the postponement of the December 2025 BSKE is a rider not germane to the subject matter of the law.
• COMELEC Encroachment: Hidalgo et al. argued that RA 12232 encroaches on COMELEC's power to regulate matters pertaining to the conduct of elections, which necessarily includes the power to suspend or postpone elections.

• Presidential Immunity: The OSG argued that President Marcos Jr., identified as a respondent in the Tayam Petition, should be dropped from the case as he enjoys immunity from suit.
• Hierarchy of Courts: The OSG asserted that the petitions should be dismissed for violating the doctrine of hierarchy of courts, and that the remedies of mandamus and declaratory relief are not proper.
• Term-Setting Character: The OSG maintained that since RA 12232 is primarily a term-setting law, the guidelines set in Macalintal should not apply to determine its constitutionality.
• Equal Protection: The OSG argued that the law does not violate the equal protection clause since BSK officials are not similarly situated as other local elected officials.
• Legitimate Public Purpose: The OSG averred that the term-setting provision was enacted in pursuit of a legitimate public purpose, namely mitigating typhoon risks, logistical issues, and decoupling the BSKE from national and local elections.
• Incidental Effects: The OSG insisted that the consequences of the term-lengthening provision—the one-year postponement of the BSKE and the hold-over of incumbent officials—are the logical result of the primary intent of the law and do not violate the people's right to regular and periodic elections.
• One Subject-One Title: The OSG maintained that the challenged law does not violate the "one title-one subject" rule since all provisions are related and germane to the subject matter of fixing the term of BSK officials.
• Plenary Power Over Qualifications: The OSG disputed the allegation that the change in the schedule disenfranchised voters, contending that it is within the plenary power of Congress to set the qualifications for SK elections.
• Intervention — Presumption of Validity: The LNB et al. argued that RA 12232 is presumed valid and that Macalintal failed to adduce evidence of a clear constitutional breach. They contended that Congress enacted the law pursuant to constitutional provisions, that it is a term-setting law whose postponement effect is only incidental, and that even if measured against Macalintal standards, valid grounds exist for the postponement. They further argued that the law does not violate suffrage, is not given retroactive effect, does not violate equal protection, does not violate the one-subject-one-title rule, and that the Macalintal Petition was prematurely filed before the lapse of 15 days from the law's publication.

• Intervention: Whether the Liga ng mga Barangay sa Pilipinas and the punong barangays should be allowed to intervene in the consolidated cases.
• Presidential Immunity: Whether President Ferdinand R. Marcos Jr. should be dropped as a respondent in the consolidated cases.
• Judicial Review: Whether the requisites for the Court's exercise of its power of judicial review are present.
• Hierarchy of Courts: Whether the petitioners violated the doctrine of hierarchy of courts by filing directly with the Supreme Court.
• Nature of the Law: Whether Republic Act No. 12232 is a term-setting law or an election postponement law, and whether the Macalintal guidelines apply.
• One Subject-One Title: Whether Republic Act No. 12232 violates the one-subject-one-title rule under Article VI, Section 26(1) of the Constitution.
• Right to Suffrage: Whether Republic Act No. 12232 violates the constitutional right to suffrage.
• Equal Protection: Whether Republic Act No. 12232 violates the equal protection clause.

• Intervention: No. The LNB et al. failed to show that they were duly authorized by their purported principals to act on the latter's behalf, and failed to demonstrate a direct and immediate legal interest in the outcome of the litigation.
• Presidential Immunity: Yes. President Marcos Jr. was dropped as a respondent, the President being immune from suit during tenure in office.
• Judicial Review: Yes. All four requisites for judicial review—actual case or controversy, locus standi, earliest opportunity, and lis mota—were satisfied.
• Hierarchy of Courts: No violation. Direct recourse to the Court was justified because the issues involved genuine questions of constitutionality that were pure questions of law and of transcendental importance.
• Nature of the Law: Republic Act No. 12232 is a term-setting law, not an election postponement law. The Macalintal guidelines, which apply to postponement laws, are inapplicable.
• One Subject-One Title: No violation. All provisions of RA 12232 are related and germane to the single subject expressed in its title—setting the term of office of BSK officials.
• Right to Suffrage: No violation. The law merely exercises Congress's express constitutional authority to determine the term of barangay officials; elections remain regular, periodic, and certain, merely occurring every four years instead of three.
• Equal Protection: No violation. The Constitution itself differentiates barangay officials from other local officials by expressly delegating their term to congressional determination, and substantial distinctions exist between barangays and other local government units.

• Intervention: Intervention requires both a legal interest in the matter in litigation and a showing that the intervention will not unduly delay or prejudice the adjudication of the rights of the original parties. Under Rule 19 of the Rules of Court, the interest must be of a direct and immediate character such that the intervenor will either gain or lose by the direct legal operation of the judgment. The LNB et al. failed on three grounds. First, the individuals who filed the Petition-In-Intervention failed to prove they were duly authorized by their purported principals. While the LNB resolution showed the LNB resolved to intervene, it did not mention that it authorized its president, Dy, to execute certifications and file the petition on its behalf. Similarly, the barangay resolutions showed the sanggunians resolved to intervene but did not mention authorization for the punong barangays to execute certifications and file pleadings. Second, assuming the barangay captains were duly authorized, the barangays themselves lacked direct and immediate interest: regardless of whether the December 2025 BSKE pushes through, there will always be elected BSK officials in place, and the barangays have no interest in ensuring that specific officials serve three years. Third, even assuming the petition was filed in the punong barangays' individual capacities, they admitted they were aware prior to election that they would serve only two years in light of Macalintal. Public office is a public trust, not a property right, and no one has a vested right to hold public office or an expectancy thereof.

• Presidential Immunity: The President is immune from suit during tenure in office. This immunity exists to preserve the dignity of the high office and to free the President from harassment, hindrance, or distraction in the performance of official duties. The President remains accountable to the people but may be removed only by impeachment. Accordingly, President Marcos Jr. was dropped as a respondent.

• Judicial Review: All four requisites were satisfied. First, an actual case or controversy existed: there was a clear contrariety of legal rights between Congress's power to regulate elections and the citizenry's exercise of suffrage, and petitioners' allegations sufficiently established a prima facie case of constitutional violation. Second, petitioners had locus standi: as voters and taxpayers, they demonstrated an actual and direct violation of their right to participate in the BSKE, or at least an imminent threat thereof, and a prima facie showing of grave abuse of discretion. Third, the issue of constitutionality was raised at the earliest opportunity—the first petition was filed a mere two days after the law was signed. Fourth, the constitutional question was the lis mota: the principal relief sought was declaration of unconstitutionality, and the case could not be resolved on any other ground.

• Hierarchy of Courts: While the Court, the Court of Appeals, and the RTCs have concurrent original jurisdiction over petitions for certiorari, prohibition, mandamus, quo warranto, and habeas corpus, the doctrine of hierarchy of courts generally requires recourse first to the lower-ranked court. However, the Court has allowed direct recourse based on special and important reasons, including genuine issues of constitutionality, transcendental importance, and pure questions of law. Here, whether RA 12232 violated the right to suffrage and/or the equal protection clause presented genuine constitutional issues that were pure questions of law, resolvable without presentation of evidence. Direct recourse was therefore justified.

• Nature of the Law: The Court conducted a detailed comparison between RA 12232 and RA 11935 (the law struck down in Macalintal), identifying four key differences. First, the titles differ: RA 12232 is titled "An Act Setting the Term of Office," while RA 11935 is titled "An Act Postponing the December 2022 Barangay and Sangguniang Kabataan Elections." Second, RA 12232 makes no reference to or amendment of RA 9164, whereas every prior postponement law expressly amended RA 9164. Third, RA 12232 provides a new four-year term, while RA 11935 maintained the existing three-year term under RA 9164. Fourth, RA 12232 sets the election interval at every four years, while RA 11935 maintained every three years. Applying the plain meaning rule (verba legis), the Court found that RA 12232's structure, language, and organization demonstrate it is fundamentally a term-setting law. By analogy to the primary purpose doctrine—where the legal nature of governmental action is determined by its primary objective, not secondary or incidental effects—the Court concluded that RA 12232's principal purpose is to exercise Congress's express constitutional authority under Article X, Section 8 by establishing a four-year term. The adjustment of election dates is a necessary implementation mechanism, not an independent objective. The Macalintal guidelines were formulated against a backdrop of laws that never changed the term of office of BSK officials—pure postponement laws that moved election dates while keeping the three-year term constant. Those guidelines presume a legal framework where postponement means delaying elections without changing terms, and thus provide no authoritative guidance on term-setting laws. Applying postponement-specific guidelines to a term-setting law would create a constitutional paradox where fulfilling an express constitutional duty triggers restrictions designed for an entirely different type of legislative action.

• One Subject-One Title: The Court has consistently applied a liberal and flexible interpretation of the one-subject-one-title rule. The rule is sufficiently complied with if the title is comprehensive enough to include the general object the statute seeks to effect. RA 12232's single subject is prescribing a new term for BSK officials, precisely as stated in its title. The supposedly separate subjects in its provisions—the date of election, assumption of office, and hold-over—are necessary components of establishing the new four-year term structure, not unrelated matters inappropriately bundled together.

• Right to Suffrage: The right to suffrage guarantees that citizens will elect their officials through regular elections but does not mandate any specific electoral frequency or term length for BSK officials. The Constitution itself establishes varying term lengths—six years for the President and senators, three years for representatives and local officials—and delegates the determination of barangay officials' terms to Congress. When the Constitution authorizes Congress to make this determination, the exercise of that express power cannot simultaneously violate the Constitution. RA 12232 does not abolish, suspend, or indefinitely postpone elections; it simply establishes that the BSKE will be held every four years instead of every three. The elections remain regular, periodic, and certain. No citizen is deprived of any political right, and the democratic character of barangay governance is fully preserved.

• Equal Protection: The Constitution itself provides differentiated treatment for barangay officials: while it fixes three-year terms for other elective local officials, it expressly exempts barangay officials and delegates their term to congressional determination. Any legislation governing barangay officials' terms may, by definition, necessarily deviate from the term of other local officials. The mere fact that a law treats barangay officials differently cannot constitute "undue favor" or an equal protection violation when such differential treatment is constitutionally provided. Moreover, substantial distinctions exist between barangays and other local government units: the barangay is the primary planning and implementing unit of government policies, the most basic political unit, and the first and most direct line of service between government and the people, involving smaller constituencies, more intimate community relationships, and less complex administrative machinery.

• Doctrine of Necessary Implication — What is implied in a statute is as much a part of it as what is expressed; every grant of power necessarily includes all incidental powers required to effectuate its purpose. The Court applied this doctrine to hold that when Article X, Section 8 granted Congress the power to determine the term of office of barangay officials, this express grant necessarily carries with it the power to determine when that term begins and ends, pursuant to the maxim in eo plus sit, simper inest et minus (the greater includes the lesser). The temporal designation of the start of the new term is as much a part of the legislative power as if expressly enumerated by the Constitution.

• Primary Purpose Doctrine — The legal nature of governmental action is determined by its primary objective, not by its secondary or incidental effects. The Court applied this by analogy to hold that RA 12232's principal purpose is term-setting, not election postponement; any adjustment in election timing is a necessary implementation mechanism, not an independent objective. The doctrine was originally applied in distinguishing between tax and regulation as exercises of police power.

• Plain Meaning Rule (Verba Legis) — When the law is clear and unambiguous, the court must give it its literal meaning and apply it without interpretation. The Court relied on this rule to determine RA 12232's fundamental character as a term-setting law from its title and provisions, which plainly speak of "setting the term of office."

• Macalintal Guidelines on Election Postponement — Five-point criteria for evaluating the validity of laws postponing elections: (1) postponement is the exception to the rule of regular, periodic elections; (2) postponement must be justified by sufficiently important, substantial, or compelling reasons; (3) the electorate must still be guaranteed an effective opportunity to exercise suffrage; (4) postponement must be reasonably appropriate and narrowly tailored; and (5) postponement must not violate the Constitution or existing laws. The Court held these guidelines inapplicable to RA 12232 because they were formulated for pure postponement laws that never changed the term of office of BSK officials.

• Intervention — Intervention requires concurrence of two requisites: (a) the movant must have a legal interest in the matter in litigation, or be otherwise qualified; and (b) consideration must be given as to whether the adjudication of the rights of the original parties may be delayed or prejudiced, or whether the intervenor's rights may be protected in a separate proceeding. The legal interest must be of a direct and immediate character such that the intervenor will either gain or lose by the direct legal operation of the judgment—not indirect, contingent, remote, conjectural, consequential, or collateral.

• Presidential Immunity from Suit — The President, during tenure of office or actual incumbency, may not be sued in any civil or criminal case. This immunity exists to preserve the dignity of the high office and to free the President from harassment or distraction in the performance of official duties. The President remains accountable to the people but may be removed only by impeachment.

• Doctrine of Hierarchy of Courts — Exceptions — While recourse must generally first be made to the lower-ranked court exercising concurrent jurisdiction, direct recourse to the Supreme Court is allowed based on special and important reasons, including: (1) genuine issues of constitutionality requiring immediate address; (2) issues of transcendental importance; (3) cases of first impression; (4) constitutional issues better decided by the Court; (5) exigency; (6) review of acts of a constitutional organ; (7) no other plain, speedy, and adequate remedy; and (8) questions dictated by public welfare or the broader interest of justice. The decisive factor is whether the issue involves a pure question of law.

• "Republic Act No. 12232 is a term-setting law that falls squarely under Congress's express constitutional authority under Article X, Section 8 of the Constitution to 'determine by law' the term of office of barangay officials. The law's central and animating purpose is establishing four-year terms for the BSK officials." — This passage articulates the ratio decidendi: the characterization of RA 12232 as a term-setting law, which removes it from the scope of the Macalintal guidelines.

• "The Constitution cannot be read to simultaneously command Congress to determine barangay officials' terms while simultaneously subjecting every such determination to limitations meant for laws that merely delay elections for exigent circumstances." — This passage addresses the constitutional paradox the Court identified in applying postponement-specific guidelines to term-setting legislation, reinforcing the differentiated treatment between the two categories of laws.

• "An election is 'regular' if it occurs at fixed, predictable intervals established by law, regardless of whether those intervals are two, three, four, or five years." — This defines the Court's understanding of what constitutes a "regular" election for purposes of the right to suffrage, supporting the conclusion that a four-year interval does not violate suffrage.

• "The right to suffrage guarantees that citizens will elect their officials through regular elections—it does not mandate any specific electoral frequency or term length for the BSK officials." — This passage delineates the scope of the constitutional right to suffrage as it pertains to barangay-level elections, distinguishing the guarantee of regular elections from a mandate for any particular term length.

• Atty. Macalintal vs. Commission on Elections, 943 Phil. 212 (2023) — The controlling precedent establishing five-point guidelines for evaluating election postponement laws. The Court distinguished RA 12232 from the law invalidated in Macalintal (RA 11935), holding the guidelines inapplicable to term-setting legislation. The decision extensively compared the two laws' titles, amendatory history, term provisions, and election intervals to demonstrate their fundamentally different characters.

• Republic vs. Rubin, 887 Phil. 600 (2020) — Cited for the requisites of intervention under Rule 19 of the Rules of Court, particularly the requirement that the intervenor's interest must be of a direct and immediate character such that the intervenor will either gain or lose by the direct legal operation of the judgment.

• Kida vs. Senate of the Philippines, 675 Phil. 316 (2011) — Cited for the principle that Congress's legislative power is broad, general, and comprehensive, encompassing all subjects of general concern unless the Constitution has lodged the power elsewhere.

• Chevron Philippines, Inc. vs. Bases Conversion and Development Authority, 645 Phil. 84 (2010) — Cited for the primary purpose doctrine, applied by analogy to determine that RA 12232's legal nature is determined by its primary objective (term-setting) rather than its incidental effects (postponement of elections).

• Fariñas vs. The Executive Secretary, 463 Phil. 179 (2003) — Cited for the liberal and flexible interpretation of the one-subject-one-title rule, holding that the title need not be an abstract or index of the Act, and that it is sufficient if the title is comprehensive enough to include the general object the statute seeks to effect.

• Prof David vs. Pres. Macapagal-Arroyo, 522 Phil. 705 (2006) — Cited for the doctrine of presidential immunity from suit during tenure of office.

• GIOS-SAMAR, Inc. vs. Department of Transportation and Communications, 849 Phil. 120 (2019) — Cited for the principle that the Court allows direct recourse only when the issue involves a pure question of law, clarifying that the nature of the question raised—not merely the presence of exceptions—determines whether direct recourse is proper.

• Article X, Section 8, 1987 Constitution — Provides that the term of office of elective local officials, except barangay officials which shall be determined by law, shall be three years. The Court held that this provision expressly delegates to Congress the authority—and imposes the duty—to determine the term of office of barangay officials, including the incidental power to fix the commencement and termination dates of that term by necessary implication.

• Article VI, Section 26(1), 1987 Constitution — Requires that every bill passed by Congress shall embrace only one subject which shall be expressed in the title thereof. The Court held that RA 12232 complies with this requirement because all its provisions are germane to the single subject of setting the term of office of BSK officials.

• Article VIII, Section 1, 1987 Constitution — Vests judicial power in the Supreme Court and lower courts, including the duty to settle actual controversies and determine grave abuse of discretion. The Court relied on this provision to establish both traditional and expanded judicial review, finding all requisites satisfied.

• Article V, 1987 Constitution — Dedicated to suffrage. The Court held that RA 12232 does not infringe the right to suffrage because the right guarantees regular elections but does not mandate any specific electoral frequency or term length for BSK officials.

• Article II, Section 1, 1987 Constitution — Declares the Philippines a democratic and republican state with sovereignty residing in the people. The Court invoked this provision to frame the relationship between suffrage, representation, and elections as the foundational architecture of Philippine democracy.

• Article IX(C), Section 9, 1987 Constitution — Provides that the election period shall commence ninety days before the day of election and end thirty days thereafter, unless otherwise fixed by COMELEC. The Court read this provision in conjunction with Congress's power to fix the commencement of the BSK term, noting that the election must fall within a date consistent with the election period and before the date of assumption into office.

• Article III, Section 1, 1987 Constitution — Guarantees the right against deprivation of life, liberty, or property without due process of law and the equal protection of the laws. The Court found no violation, holding that the Constitution itself differentiates barangay officials from other local officials and that substantial distinctions justify different regulatory treatment.

• Rule 19, Rules of Court — Governs intervention, requiring a legal interest in the matter in litigation and consideration of whether intervention will unduly delay or prejudice the adjudication of the rights of the original parties. The Court applied this rule to deny the LNB et al.'s Petition-In-Intervention.

• Section 384, Local Government Code — Defines the barangay as the primary planning and implementing unit of government policies and as a forum for the collective views of the people. The Court cited this provision to support the finding that substantial distinctions exist between barangays and other local government units, justifying different regulatory treatment under the equal protection clause.

Gesmundo, C.J., Zalameda, Gaerlan, Rosario, Dimaampao, Marquez, and Villanueva, JJ., concurred. Hernando and Lazaro-Javier, JJ., were on official business.

• Leonen, SAJ — Maintained that the strict scrutiny test must be applied in reviewing statutes that postpone elections, as any legislative act that impedes the exercise of the right of suffrage, however lightly, must pass strict scrutiny. Argued that RA 12232 indisputably affects the constitutional right to suffrage by postponing the BSKE, and that the postponement frustrates the reasonable expectation of registered voters that they would exercise suffrage on the first Monday of December 2025 as pronounced in Macalintal. Voted to grant the consolidated petitions.

• Caguioa, J. — Argued that the postponement and hold-over provisions of RA 12232, though embedded within a term-setting statute, are distinct, severable, and independently subject to constitutional scrutiny. Contended that these provisions defer the people's right to vote without legitimate or compelling justification and extend incumbents' mandates beyond the authority conferred by the electorate, violating substantive due process and the right of suffrage. Applied the Macalintal guidelines to the postponement provisions and found them unconstitutional, noting that the legislative justifications—cost savings, administrative burden, and shortness of term—were precisely the kinds of superficial reasons already rejected in Macalintal. Characterized the hold-over as a legislative appointment, creating an eleven-month gap during which officials continue in office without renewed democratic consent. Voted to partially grant the petitions and declare Sections 2, 3, and 4 unconstitutional. Inting, J., joined this dissent.

• Kho, Jr., J. — Contended that RA 12232 is in essence a postponement of the BSK elections, as it sets the election date to a date later than that provided under existing law, and that calling it a term-setting law is a distinction without difference. Argued that the law fails the due process test for lack of a legitimate governmental interest and reasonable necessity, that Sections 2, 3, and 4 are riders violating the one-subject-one-title rule because the term of office is separate and distinct from the date of elections, and that the postponement failed to comply with the Macalintal guidelines. Voted to grant the petitions and declare RA 12232 unconstitutional.

• Singh, J. — Dissented on two points. First, disagreed with the denial of the Petition-In-Intervention, arguing that the punong barangays demonstrated direct and immediate interest as elected officials whose terms of office, capacity to hold office, and eligibility for re-election are directly affected, and that they may be granted locus standi as voters. Second, agreed that Section 1 (term-setting) is valid but argued that Sections 2 and 4, which postpone the BSKE and provide for hold-over, must be scrutinized under the Macalintal guidelines. Maintained that strict scrutiny should apply to election postponements, and that the law provides no compelling reason for an eleven-month delay. Voted to partly grant the petitions and declare Sections 2 and 4 unconstitutional.