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AGRIPINO A. DE GUZMAN v. COMELEC

FACTS:

This case involves a petition to declare Section 44 of Republic Act No. 8189 (RA 8189) as unconstitutional. RA 8189, also known as "The Voter's Registration Act of 1996," was enacted on June 10, 1996 and approved by President Fidel V. Ramos on June 11, 1996. Section 44 of RA 8189 provides for the reassignment of Election Officers, stipulating that no Election Officer shall hold office in a particular city or municipality for more than four years. Any election officer who has served for at least four years in a particular city or municipality shall be automatically reassigned by the Commission on Elections (COMELEC) to a new station outside the original congressional district. The COMELEC promulgated Resolution Nos. 97-0002 and 97-0610 for the implementation of Section 44. Thereafter, the COMELEC issued directives reassigning the petitioners, who are City or Municipal Election Officers, to different stations. Aggrieved by the reassignments, the petitioners filed the present petition questioning the validity of Section 44 of RA 8189, arguing that it violates several constitutional provisions, including the equal protection clause, security of tenure of civil servants, due process, and the independence of the COMELEC.

ISSUES:

  1. Whether or not Section 44 of RA 8189 violates the equal protection clause of the Constitution.

  2. Whether or not Section 44 of RA 8189 violates the constitutional guarantee on security of tenure of civil servants.

  3. Whether or not Section 44 of RA 8189 constitutes a deprivation of property without due process of law.

  4. Whether or not Section 44 of RA 8189 undermines the constitutional independence of COMELEC.

  5. Whether or not Section 44 of RA 8189 contravenes the constitutional requirement that every bill passed by Congress shall embrace only one subject.

  6. Whether or not Section 44 of RA 8189 is void for failure to comply with the constitutional requirement of three readings on separate days and distribution of printed copies before its passage.

RULING:

  1. The Court held that Section 44 of RA 8189 is valid and constitutional. The classification under Section 44 satisfies the requirements of the equal protection clause. The singling out of election officers is justified to ensure the impartiality of election officials by preventing familiarity with the people of their place of assignment. The Court also ruled that Section 44 does not violate the constitutional guarantee on security of tenure, does not constitute a deprivation of property without due process of law, does not undermine the constitutional independence of COMELEC, does not contravene the constitutional requirement of one subject, and is not void for failure to comply with the constitutional requirement of three readings on separate days.

PRINCIPLES:

  • The equal protection clause of the Constitution permits a valid classification that rests on substantial distinctions, is germane to the purpose of the law, is not limited to existing conditions only, and applies equally to all members of the same class.

  • Underinclusiveness is not an argument against a valid classification.

  • Legislation is not required to adhere to a policy of "all or none."

  • The classification under Section 44 of RA 8189 satisfies the requirements for a valid classification.