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SENATOR BENIGNO SIMEON C. AQUINO III v. COMELEC

FACTS:

Senator Benigno Aquino III and Mayor Jesse Robredo filed a petition to nullify Republic Act No. 9716, which created an additional legislative district in Camarines Sur. Prior to the enactment of this law, the province had four legislative districts. The petitioners argued that the new configuration, which resulted in a first district population of only 176,383, is unconstitutional because it falls below the minimum population requirement of 250,000 for the creation of a legislative district.

The petitioners contended that the framers of the 1987 Constitution intended to adopt a population minimum of 250,000 in creating additional legislative seats. They argued that this requirement is based on the population constant used during the distribution of the initial 200 legislative seats. However, there is no specific provision in the Constitution explicitly stating this requirement.

On the other hand, the respondents argued that the 250,000 population requirement only applies to the creation of a legislative district in a city and not in a province. They claimed that there is no fixed population requirement for the reapportionment of districts in provinces.

Additionally, the respondents raised procedural lapses, stating that the petitioners failed to allege that the respondents acted without or in excess of jurisdiction, or with grave abuse of discretion. They also argued that the petitioners had other available legal remedies and lacked the required legal standing to question the constitutionality of Republic Act No. 9716.

The Court was tasked with determining whether a minimum population of 250,000 is required for the creation of a new legislative district in a province, as interpreted by the petitioners, or if there is no fixed population requirement for the reapportionment of districts in provinces, as argued by the respondents.

ISSUES:

  1. Whether the 250,000 minimum population requirement applies to provinces in order to be entitled to a legislative district.

  2. Whether the interpretation in Mariano, Jr. v. COMELEC that the 250,000 minimum population requirement applies only to the initial legislative district of cities should also apply to additional districts in provinces.

  3. Whether the population requirement of "at least two hundred fifty thousand" is an absolute minimum for one legislative district.

  4. Whether population was the sole determinant in the determination of the precise district within the province.

  5. Whether the inclusion of Puerto Princesa in the northern towns of Palawan violates the requirement of compact, adjacent, and contiguous legislative districts.

  6. Whether the districting of Palawan and Benguet, as approved by the Body, complies with the constitutionally required threshold of 250,000 population for each district.

  7. Whether the consideration of contiguity, importance of towns and city, and common interests in line with compactness are valid factors in district apportionment.

  8. Whether the Province of Camarines Sur is entitled to an additional legislative district despite not meeting the population requirement of 250,000.

  9. Whether the reapportionment of the first and second legislative districts in the Province of Camarines Sur that resulted in the creation of a new legislative district is valid even if the population of the new district is below 250,000.

RULING:

  1. The 250,000 minimum population requirement does not apply to provinces. The second sentence of Section 5(3), Article VI of the Constitution requires a 250,000 minimum population only for a city to be entitled to a representative, but not so for a province.

  2. The interpretation in Mariano, Jr. v. COMELEC that the 250,000 minimum population requirement applies only to the initial legislative district of cities should also apply to additional districts in provinces.

  3. The requirement of "at least two hundred fifty thousand" population is not an absolute minimum for one legislative district.

  4. Population was not the sole determinant in the determination of the precise district within the province.

  5. The inclusion of Puerto Princesa in the northern towns of Palawan does not violate the requirement of compact, adjacent, and contiguous legislative districts.

  6. No, the districting of Palawan and Benguet does not comply with the constitutionally required threshold of 250,000 population for each district. The districting was based on the importance of towns and city, and not on population figures.

  7. Yes, the consideration of contiguity, importance of towns and city, and common interests in line with compactness are valid factors in district apportionment. The Constitution does not require mathematical exactitude or rigid equality in population sizes of districts. What is required is that every legislative district should comprise contiguous, compact, and adjacent territory.

  8. The Province of Camarines Sur is entitled to an additional legislative district even if it does not meet the population requirement of 250,000. The Constitution allows for the creation of additional districts in provinces and cities entitled to two districts in addition to the four given in the 1986 apportionment. The population of Camarines Sur is based on the formula and constant number used by the Constitutional Commission in national apportioning of legislative districts. Therefore, the creation of an additional district, as provided for in Republic Act No. 9786, is valid.

  9. The reapportionment of the first and second legislative districts in the Province of Camarines Sur that resulted in the creation of a new legislative district is valid even if the population of the new district is below 250,000. The considerations for redistricting and the creation of a new district in the Ordinance go beyond population and include factors such as dialects spoken, size of original groupings, natural division, and balancing of areas. The absence of abuse of discretion and the balancing of various factors support the validity of Republic Act No. 9716.

PRINCIPLES:

  • Laws enacted by Congress carry with them the presumption of constitutionality.

  • Before a law may be declared unconstitutional, there must be a clear showing that a specific provision of the constitution has been violated.

  • The provision in the Constitution that requires a 250,000 minimum population for legislative districts applies only to cities, not to provinces.

  • The interpretation of a provision in the Constitution in Mariano, Jr. v. COMELEC regarding the 250,000 minimum population requirement for cities should also be applied to provinces.

  • The population requirement of "at least two hundred fifty thousand" is used to determine how many districts a province, city, or Metropolitan Manila should have.

  • The determination of the precise district within the province considers factors other than population.

  • Legislative district must be compact, adjacent, and contiguous.

  • The Constitution does not require mathematical exactitude or rigid equality in population sizes of districts. It only requires that every legislative district should comprise contiguous, compact, and adjacent territory. (Bagabuyo v. COMELEC)

  • The consideration of contiguity, importance of towns and city, and common interests in line with compactness are valid factors in district apportionment. (Bagabuyo v. COMELEC)

  • The population of 250,000 is not a constitutional requirement for the creation of an additional legislative district if other factors are considered.

  • The composition of additional districts should consider factors such as dialects spoken, size of groupings, natural division, and balancing of areas, in addition to population.