Primary Holding

R.A. No. 6735 is inadequate to implement constitutional amendments through people’s initiative; COMELEC Resolution No. 2300 is void; and the COMELEC must dismiss the Delfin Petition.

Background

Private respondent Jesus Delfin filed a petition with the COMELEC to lift term limits for elected officials via people’s initiative under Article XVII of the Constitution. Petitioners, including Senator Miriam Defensor Santiago, argued this required a specific enabling law, which Congress had not passed.

Facts

• 1. Delfin’s petition sought COMELEC assistance in gathering signatures for a constitutional amendment to remove term limits. Petitioners argued R.A. No. 6735 was insufficient, COMELEC lacked jurisdiction, and lifting term limits constituted a revision (not an amendment) of the Constitution.

Arguments of the Petitioners

• 1. R.A. No. 6735 lacks specific provisions for constitutional initiative.
• 2. COMELEC Resolution No. 2300 is ultra vires (beyond legal authority).
• 3. Removing term limits is a revision requiring Congressional action.
• 4. No funds were allocated for constitutional initiatives.

Arguments of the Respondents

• 1. R.A. No. 6735 covers constitutional initiatives through its broad language.
• 2. COMELEC has authority to issue rules under its constitutional mandate.
• 3. Removing term limits is a mere amendment.
• 4. The petition was a valid exercise of people’s sovereign power.

Issues

• 1. Is R.A. No. 6735 sufficient to implement constitutional amendments via initiative?
• 2. Is COMELEC Resolution No. 2300 valid?
• 3. Does lifting term limits constitute a “revision” or “amendment”?
• 4. Did COMELEC have jurisdiction over Delfin’s petition without sufficient signatures?
• 5. Should the Supreme Court intervene despite pending COMELEC proceedings?

Ruling

• 1. R.A. No. 6735 is insufficient as it lacks specifics for constitutional initiatives.
• 2. COMELEC Resolution No. 2300 is void due to inadequate legislative standards.
• 3. The Delfin Petition lacked the required 12% voter signatures, rendering it invalid.
• 4. The Supreme Court held jurisdiction to prevent grave abuse of discretion.

Doctrines

• 1. Non-self-executing constitutional provisions (Article XVII, Section 2 needs legislation).
• 2. Delegation of legislative power (R.A. No. 6735 failed to provide sufficient standards for COMELEC rulemaking).
• 3. Amendment vs. Revision (Lifting term limits was not addressed due to dismissal on procedural grounds).

Key Excerpts

• 1. “The system of initiative to propose amendments… should no longer be kept in the cold; it should be given flesh and blood… Congress should not tarry in… providing implementation.”
• 2. “The right of the people to directly propose amendments… remains entombed in the cold niche of the Constitution until Congress enacts an implementing law.”

Precedents Cited

• 1. “The system of initiative to propose amendments… should no longer be kept in the cold; it should be given flesh and blood… Congress should not tarry in… providing implementation.”
• 2. “The right of the people to directly propose amendments… remains entombed in the cold niche of the Constitution until Congress enacts an implementing law.”

Statutory and Constitutional Provisions

• 1. 1987 Constitution: Article XVII, Section 2 (people’s initiative); Article VI (term limits for legislators); Article VII (presidential term limits); Article X (local term limits).
• 2. R.A. No. 6735: Sections 2 (policy), 3 (definitions), 5(b) (signature requirements), 9(b) (plebiscite effectivity).