Primary Holding

The Supreme Court ruled RA 9355 constitutional, exempting provinces composed of islands from the land area requirement under the LGC, and validated Dinagat Islands’ status as a province.

Background

Dinagat Islands was created as a province in 2006. Petitioners argued it violated LGC criteria for population (250,000) and land area (2,000 km²). After initial nullification by the Court in 2010, the case was reopened due to post-election implications for local officials, leading to the final validation of the province.

Facts

• 1. Dinagat Islands had a population of 106,951 (2006) and land area of 802.12 km², failing to meet LGC’s criteria. The LGC-IRR exempted island provinces from the land area requirement. A plebiscite and subsequent 2007/2010 elections confirmed public acceptance and operational governance.

Arguments of the Petitioners

• 1. Dinagat Islands failed constitutional and statutory requirements for province creation; the LGC-IRR’s exemption for islands is ultra vires; the province’s creation reduced Surigao del Norte’s resources unlawfully.

Arguments of the Respondents

• 1. Economic viability (₱82M income) and administrative efficiency justified exemption; the LGC-IRR’s island exemption aligns with decentralization goals; the Operative Fact Doctrine preserved Dinagat’s de facto status.

Issues

• 1. Validity of the LGC-IRR exemption for island provinces.
• 2. Constitutionality of RA 9355.
• 3. Applicability of the Operative Fact Doctrine to Dinagat’s existence.
• 4. Legality of recalling the entry of judgment to address post-election consequences.

Ruling

• 1. The Supreme Court upheld RA 9355’s constitutionality, exempting island provinces from the Local Government Code’s (LGC) land area requirement based on valid statutory interpretation of the LGC’s Implementing Rules and Regulations (IRR).
• 2. The Court reversed its 2010 decision, accepting the plea to recall the entry of judgment due to the “transcendental public importance” of maintaining Dinagat Islands’ provincial status post-2010 elections.
• 3. Legislative intent and the constitutional mandate to promote local autonomy superseded strict compliance with population/land area metrics, as Dinagat demonstrated economic viability (₱82M annual income).
• 4. The LGC-IRR’s exemption for island provinces (Art. 9(2)) was deemed consistent with congressional intent to prioritize geographic necessity and administrative efficiency.
• 5. Applied the Operative Fact Doctrine to recognize Dinagat’s de facto governance and protect the validity of past elections, appointments, and acts as a province.
• 6. Rejected petitioners’ ultra vires argument, stating the IRR provision was a valid exercise of rule-making authority under the LGC.
• 7. Emphasized that Dinagat’s creation fulfilled decentralization goals under the 1987 Constitution, enhancing governance and public service delivery.

Doctrines

• 1. Operative Fact Doctrine: Recognized Dinagat’s existence and governance pre-invalidation.
• 2. Locus Standi: Intervenors had legal standing due to direct impact on their elected positions.
• 3. Liberal Construction of Local Autonomy: Favored decentralization and self-reliance.

Key Excerpts

• 1. “The ‘moot and academic’ principle is not a magical formula that can automatically dissuade the courts from resolving a case” (addressing public interest exceptions).
• 2. “Ratio legis est anima. The spirit rather than the letter of the law” (emphasizing legislative intent).

Precedents Cited

• 1. David v. Macapagal-Arroyo: Allowed intervention for public interest despite technicalities.
• 2. League of Cities v. COMELEC: Upheld legislative intent over literal statutory interpretation.

Statutory and Constitutional Provisions

• 1. 1987 Constitution, Art. X, Sec. 10: LGC criteria for local government creation.
• 2. Local Government Code, Sec. 461: Province creation requirements (income, population, land area).
• 3. LGC-IRR, Art. 9(2): Exemption from land area for island provinces.
• 4. COMELEC Resolution 8790: Guidelines for elections if Dinagat’s status changed.