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RAUL L. LAMBINO v. COMELEC

FACTS:

On February 15, 2006, petitioners Raul L. Lambino and Erico B. Aumentado, alongside various groups and individuals referred to collectively as the "Lambino Group," began gathering signatures for an initiative petition to amend the 1987 Philippine Constitution. The Lambino Group's petition sought support from at least 12% of all registered voters nationally, with a minimum of 3% from each legislative district. By August 25, 2006, the Lambino Group had collected over 6.3 million signatures purportedly verified by COMELEC election registrars. The initiative aimed to shift the current bicameral-presidential system to a unicameral-parliamentary system and included modifications to Articles VI and VII of the Constitution, along with new Transitory Provisions under Article XVIII. They subsequently filed a petition with the COMELEC to hold a plebiscite for ratifying the proposed amendments.

On August 30, 2006, the Lambino Group filed an amended petition with COMELEC to reflect certain modifications. However, on August 31, 2006, COMELEC dismissed the petition, citing the lack of an enabling law to govern constitutional amendments via a people’s initiative, based on a precedent set by Santiago v. COMELEC, which declared RA 6735 inadequate for constitutional amendment proposals.

In response, the Lambino Group filed a petition for certiorari and mandamus with the Supreme Court in G.R. No. 174153, arguing that COMELEC committed grave abuse of discretion and that the Supreme Court's ruling in Santiago was not binding upon them. They also contended their petition embodied the "will of the sovereign people." Parallel to this, in G.R. No. 174299, petitioners led by Jejomar Binay ("Binay Group") opposed the initiative, emphasizing COMELEC's violation of a permanent injunction from the Santiago decision. Additionally, the Solicitor General supported the Lambino Group's petition. Several interventions were filed by different groups, either supporting or opposing the initiative, focusing on the validity of the signature-gathering process, standing of the Lambino Group, and the nature of the proposed amendments. The Supreme Court heard oral arguments on September 26, 2006, and received memoranda thereafter for resolution.

ISSUES:

  1. Whether the Lambino Group's initiative petition complies with Section 2, Article XVII of the Constitution on amendments to the Constitution through a people's initiative.

  2. Whether this Court should revisit its ruling in Santiago declaring RA 6735 "incomplete, inadequate or wanting in essential terms and conditions" to implement the initiative clause on proposals to amend the Constitution.

  3. Whether the COMELEC committed grave abuse of discretion in denying due course to the Lambino Group's petition.

RULING:

  1. The Lambino Group's initiative petition does not comply with Section 2, Article XVII of the Constitution. The Lambino Group failed to meet the basic requirements of the Constitution for conducting a people's initiative, such as showing the full text of the proposed amendments to the signatories before they signed the petition.

  2. There is no need to revisit** Santiago** as the present petition warrants dismissal based alone on the Lambino Group's glaring failure to comply with the basic requirements of the Constitution.

  3. The COMELEC did not commit grave abuse of discretion in denying due course to the Lambino Group's petition. The COMELEC followed the Court's ruling in Santiago, and for complying with the Court's directives, no grave abuse of discretion is attributable to the COMELEC.

PRINCIPLES:

  1. Initiative Petition Requirements: The full text of the proposed amendments must be presented to and signed by the people.

  2. Amendments vs. Revisions: A people's initiative can only propose amendments, not revisions, to the Constitution.

  3. Legal Doctrine: Courts avoid revisiting constitutional rulings if the case can be resolved on existing grounds.

  4. Grave Abuse of Discretion: No grave abuse of discretion arises when lower bodies follow the Supreme Court's directives.