MODULE 8 - ARTICLE VI – LEGISLATIVE DEPARTMENT

Section 1
The Legislative power shall be vested in the Congress of the Philippines which shall consist of a
Senate and House of Representatives, except to the extent reserved to the people by the provision on
initiative and referendum.
a. A Bicameral Body.
>an upper house is a body that looks at problems from the national perspective and thus serves as
check on the parochial tendency of a body elected by districts
>bicameralism allows for a more careful study of legislation
>bicameralism is less vulnerable to attempts of the executive to control the legislature
b. Nature of Legislative power.
>the authority to make laws and to alter and repeal them. As vested by the Constitution in
Congress, it is a derivative and delegated power
>the Consitution embodies a grant of plenary legislative power to the Philippine legislature. Thus,
any power deemed to be legislative by usage and tradition, is necessarily possessed by Congress,
unless the organic act has lodged it elsewhere
>Sec. 1 of 1987 organic law has also given legislative power to the electorate through exercise of
initiative and referendum.
>congress cannot pass irrepealable laws
c. Separation of Powers
1) R.A. 6735 (System of Initiative & Referendum)
2) Santiago vs. COMELEC [ (270 SCRA 106 (1997)]
FACTS:
In 1996, Atty. Jesus Delfin filed with COMELEC a petition to amend Constitution, to lift term limits of
elective officials, by people’s initiative. Delfin wanted COMELEC to control and supervise said people’s
initiative the signature-gathering all over the country. The proposition is: “Do you approve of lifting the
term limits of all elective government officials, amending for the purpose Sections 4 ) and 7 of Article VI,
Section 4 of Article VII, and Section 8 of Article 8 of Article X of the 1987 Philippine Constitution?”
Said Petition for Initiative will first be submitted to the people, and after it is signed by at least 12% total
number of registered voters in the country, it will be formally filed with the COMELEC.

COMELEC in turn ordered Delfin for publication of the petition. Petitioners Sen. Roco et al moved for
dismissal of the Delfin Petition on the ground that it is not the initiatory petition properly cognizable by
the COMELEC.

a. Constitutional provision on people’s initiative to amend the Constitution can only be implemented by
law to be passed by Congress. No such law has been passed
b. Republic Act No. 6735 provides for 3 systems on initiative but failed to provide any subtitle on
initiative on the Constitution, unlike in the other modes of initiative. This deliberate omission indicates
matter of people’s initiative was left to some future law.
c. COMELEC has no power to provide rules and regulations for the exercise of people’s initiative. Only
Congress is authorized by the Constitution to pass the implementing law.
d. People’s initiative is limited to amendments to the Constitution, not to revision thereof.
Extending or lifting of term limits constitutes a revision.
e. Congress nor any government agency has not yet appropriated funds for people’s initiative.

ISSUE:
Whether or not the people can directly propose amendments to the Constitution through the system of
initiative under Section 2 of Article XVII of the 1987 Constitution.
HELD:
REPUBLIC ACT NO. 6735

It was intended to include or cover people’s initiative on amendments to the Constitution but, as worded,
it does not adequately cover such initiative. Article XVII Section 2 of the 1987 Constitution providing for
amendments to Constitution, is not self-executory. While the Constitution has recognized or granted the
right of the people to directly propose amendments to the Constitution via PI, the people cannot exercise
it if Congress, for whatever reason, does not provide for its implementation.

FIRST: Contrary to the assertion of COMELEC, Section 2 of the Act does not suggest an initiative on
amendments to the Constitution. The inclusion of the word “Constitution” therein was a delayed
afterthought. The word is not relevant to the section which is silent as to amendments of the Constitution.

SECOND: Unlike in the case of the other systems of initiative, the Act does not provide for the contents
of a petition for initiative on the Constitution. Sec 5(c) does not include the provisions of the Constitution
sought to be amended, in the case of initiative on the Constitution.

THIRD: No subtitle is provided for initiative on the Constitution. This conspicuous silence as to the latter
simply means that the main thrust of the Act is initiative and referendum on national and local laws. The
argument that the initiative on amendments to the Constitution is not accepted to be subsumed under the
subtitle on National Initiative and Referendum because it is national in scope. Under Subtitle II and III,
the classification is not based on the scope of the initiative involved, but on its nature and character.
National initiative – what is proposed to be enacted is a national law, or a law which only Congress can
pass.
Local initiative – what is proposed to be adopted or enacted is a law, ordinance or resolution which only
legislative bodies of the governments of the autonomous regions, provinces, cities, municipalities, and
barangays can pass.
Potestas delegata non delegari potest

What has been delegated, cannot be delegated. The recognized exceptions to the rule are: [1] Delegation
of tariff powers to the President; [2] Delegation of emergency powers to the President; [3] Delegation to
the people at large; [4] Delegation to local governments; and [5] Delegation to administrative bodies.

COMELEC

Empowering the COMELEC, an administrative body exercising quasi judicial functions, to promulgate
rules and regulations is a form of delegation of legislative authority. In every case of permissible
delegation, there must be a showing that the delegation itself is valid. It is valid only if the law (a) is
complete in itself, setting forth therein the policy to be executed, carried out, or implemented by the
delegate; and (b) fixes a standard – the limits of which are sufficiently determinate and determinable – to
which the delegate must conform in the performance of his functions. Republic Act No. 6735 failed to
satisfy both requirements in subordinate legislation. The delegation of the power to the COMELEC is
then invalid.

COMELEC RESOLUTION NO. 2300

Insofar as it prescribes rules and regulations on the conduct of initiative on amendments to the
Constitution is void. COMELEC cannot validly promulgate rules and regulations to implement the
exercise of the right of the people to directly propose amendments to the Constitution through the system
of initiative. It does not have that power under Republic Act No. 6735.
Whether the COMELEC can take cognizance of, or has jurisdiction over, a petition solely intended to
obtain an order: (a) fixing the time and dates for signature gathering; (b) instructing municipal election
officers to assist Delfin’s movement and volunteers in establishing signature stations; and (c) directing or
causing the publication of the unsigned proposed Petition for Initiative on the 1987 Constitution.

DELFIN PETITION

COMELEC ACTED WITHOUT JURISDICTION OR WITH GRAVE ABUSE OF DISCRETION IN

ENTERTAINING THE DELFIN PETITION. Even if it be conceded ex gratia that RA 6735 is a full
compliance with the power of Congress to implement the right to initiate constitutional amendments, or
that it has validly vested upon the COMELEC the power of subordinate legislation and that COMELEC
Resolution No. 2300 is valid, the COMELEC acted without jurisdiction or with grave abuse of discretion
in entertaining the Delfin Petition.

The Delfin Petition does not contain signatures of the required number of voters. Without the required
signatures, the petition cannot be deemed validly initiated. The COMELEC requires jurisdiction over a
petition for initiative only after its filing. The petition then is the initiatory pleading. Nothing before its
filing is cognizable by the COMELEC, sitting en banc.

Since the Delfin Petition is not the initiatory petition under RA6735 and COMELEC Resolution No.
2300, it cannot be entertained or given cognizance of by the COMELEC. The petition was merely entered
as UND, meaning undocketed. It was nothing more than a mere scrap of paper, which should not have
been dignified by the Order of 6 December 1996, the hearing on 12 December 1996, and the order
directing Delfin and the oppositors to file their memoranda to file their memoranda or oppositions. In so
dignifying it, the COMELEC acted without jurisdiction or with grave abuse of discretion and merely
wasted its time, energy, and resources.

3) Belgica vs. Honorable Executive Secretary (G.R. No. 208566, November 19, 2013)
The grant of the rule-making power to administrative agencies must be confined to details for
regulating the mode or proceeding to carry into effect the law as it has been enacted. The power cannot
be extended to amending or expanding the statutory requirements or to embrace matters not covered by
the statute. Rules that subvert the statute cannot be sanctioned.
FACTS:
Starting 2004, several concerned citizens sought the nullification of the PDAF for being
unconstitutional and the likely source of the congressmen’s kickbacks. Unfortunately, for lack of
“any pertinent evidentiary support that illegal misuse of PDAF has been a common exercise of
unscrupulous members of the congress,” the petition was dismissed. In July 2013, the National
Bureau of Investigation began its probe into the allegations that “the government has been
defrauded of some P10 Billion over the past 10 years by a syndicate using funds from the pork
barrel.” After criminal investigations were filed following the Napoles controversy, the
Commission on Audit released its own results of a three-year audit covering the legislators’
PDAF from 2007 to 2009. The total releases amounting to billions of pesos spurred several
petitions to be lodged before the SC to declare the “Pork Barrel System” as unconstitutional.

ISSUE:
Whether or not the 2013 PDAF Article and all other Congressional Pork Barrel Laws similar
thereto are unconstitutional considering that they violate the constitutional provision on the non
delegability of legislative power. (YES)

RULING:
In the cases at bar, the Court observes that the 2013 PDAF Article, insofar as it confers
postenactment identification authority to individual legislators, violates the principle of non-
delegability since said legislators are effectively allowed to individually exercise the power of
appropriation, which is lodged in Congress.That the power to appropriate must be exercised
only through legislation is clear from Section 29(1), Article VI of the 1987 Constitution which
states that: “No money shall be paid out of the Treasury except in pursuance of an appropriation
made by law.” To understand what constitutes an act of appropriation, the Court, in Bengzon v.
Secretary of Justice and Insular Auditor held that the power of appropriation involves (a) the
setting apart by law of a certain sum from the public revenue for (b) a specified purpose.
Essentially, under the 2013 PDAF Article, individual legislators are given a personal lump-sum
fund from which they are able to dictate (a) how much from such fund would go to (b) a specific
project or beneficiary that they themselves also determine.
As these two (2) acts comprise the exercise of the power of appropriation as described in the
Bengzon case, and given that the 2013 PDAF Article authorizes individual legislators to perform
the same, undoubtedly, said legislators have been conferred the power to legislate which the
Constitution does not, however, allow. Thus, keeping with the principle of non-delegability of
legislative power, the Court hereby declares the 2013 PDAF Article, as well as all other forms of
Congressional Pork Barrel which contain the similar legislative identification feature as herein
discussed, as unconstitutional.

Section 5.
a. Composition of HOR
>When an increase of the number of legislative districts due to creation of new province or city
and results to an imbalance of the mother province, COMELEC has no authority to correct the
imbalance by transferring municipalities from one district to another. Correction of imbalance
must await the enactment of a reapportionment law.
b. Kinds of Representatives
1. District Representatives – shall be elected from legislative districts apportioned among the
provinces, cities and MM area in accordance with the number of their respective inhabitants,
and on the basis of a uniform and progressive ratio.
2. Party Representatives
3. Sectoral Representatives – lasts only for 3 consecutive terms after ratification of Constitution
c. Apportionment
>Each legislative district shall comprise, as far as practicable, contiguous, compact and adjacent
territory
>Rule of prohibition of “Gerrymandering” – the creation of representative districts out of separate
portions of territory in order to favor a candidate
d. D

3) Sema vs. COMELEC (G.R. No. 177597, July 16, 2008)

FACTS:
On Aug. 28, 2006, the ARMM Regional Assembly, exercising its power to create provinces,
created the Province of Shariff Kabunsuan composed of 8 municipalities (MMA Act 201). The
voters of Maguindanao ratified Shariff Kabunsuan’s creation in a plebiscite held on Oct. 29,
2006.

The Sangguniang Panglungsod of Cotabato City passed Resolution No. 3999 requesting
COMELEC to “clarify the status of Cotabato City in view of the conversion of the First District of
Maguindanao into a regular province”. COMELEC resolved that pending the enactment of the
appropriate law by Congress, status quo should be maintained.

However, in May 2007 elections, COMELEC issued resolution that Maguindanao’s first
legislative district composed only of Cotabato City and renamed the first district of Maguindanao
as Shariff Kabunsuan Province with Cotabato City.

Sema, who was a candidate, prayed for the nullification and the exclusion from canvassing
votes cast on Cotabato City and Shariff Kabunsuan is entitled to one representative in Congress
under Section 5 (3), Article VI of the Constitution and COMELEC has no jurisdiction in issuing
the resolution.

Respondent Dilangalen, who won as representative of said district, claimed that the
COMELEC could not reapportion Maguindanao’s first legislative district to make Cotabato City
its sole component unit as the power to reapportion legislative districts lies exclusively
with Congress, not to mention that Cotabato City does not meet the minimum population
requirement under Section 5 (3), Article VI of the Constitution for the creation of a
legislative district within a city.

ISSUE:
Whether Section 19, Article VI of RA 9054, delegating to the ARMM Regional Assembly the
power to create provinces, cities, municipalities and barangays, is constitutional

RULING:
NO. The creation of local government units is governed by Section 10, Article X of the
Constitution. Thus, the creation of any of the four local government units – province, city,
municipality or barangay – must comply with three conditions. First, the creation of a local
government unit must follow the criteria fixed in the Local Government Code. Second, such
creation must not conflict with any provision of the Constitution. Third, there must be a plebiscite
in the political units affected.
There is neither an express prohibition nor an express grant of authority in the Constitution for
Congress to delegate to regional or local legislative bodies the power to create local
government units. However, under its plenary legislative powers, Congress can delegate to
local legislative bodies the power to create local government units, subject to reasonable
standards and provided no conflict arises with any provision of the Constitution. In fact,
Congress has delegated to provincial boards, and city and municipal councils, the power
to create barangays within their jurisdiction,25 subject to compliance with the criteria
established in the Local Government Code, and the plebiscite requirement in Section 10, Article
X of the Constitution. However, under the Local Government Code, "only x x x an Act of
Congress" can create provinces, cities or municipalities.

Under Section 19, Article VI of RA 9054, Congress delegated to the ARMM Regional Assembly
the power to create provinces, cities, municipalities and barangays within the ARMM. Congress
made the delegation under its plenary legislative powers because the power to create local
government units is not one of the express legislative powers granted by the Constitution to
regional legislative bodies.27 In the present case, the question arises whether the delegation to
the ARMM Regional Assembly of the power to create provinces, cities, municipalities and
barangays conflicts with any provision of the Constitution.

There is no provision in the Constitution that conflicts with the delegation to regional legislative
bodies of the power to create municipalities and barangays, provided Section 10, Article X of the
Constitution is followed. However, the creation of provinces and cities is another matter.
Section 5 (3), Article VI of the Constitution provides, "Each city with a population of at least
two hundred fifty thousand, or each province, shall have at least one representative" in
the House of Representatives. Similarly, Section 3 of the Ordinance appended to the
Constitution provides, "Any province that may hereafter be created, or any city whose
population may hereafter increase to more than two hundred fifty thousand shall be entitled in
the immediately following election to at least one Member x x x."

Thus, the power to create a province, or a city with a population of 250,000 or more, requires
also the power to create a legislative district.

Any province that may hereafter be created, or any city whose population may hereafter
increase to more than two hundred fifty thousand shall be entitled in the immediately following
election to at least one Member or such number of Members as it may be entitled to on the
basis of the number of its inhabitants and according to the standards set forth in paragraph (3),
Section 5 of Article VI of the Constitution.

Pursuant to this Section, a representative district may come into existence: (a) indirectly,
through the creation of a province — for "each province shall have at least one member" in the
House of Representatives; or (b) by direct creation of several representative districts within a
province.

In summary, we rule that Section 19, Article VI of RA 9054, insofar as it grants to the ARMM
Regional Assembly the power to create provinces and cities, is void for being contrary to
Section 5 of Article VI and Section 20 of Article X of the Constitution, as well as Section 3 of the
Ordinance appended to the Constitution. Only Congress can create provinces and cities
because the creation of provinces and cities necessarily includes the creation of legislative
districts, a power only Congress

4) Bagabuyo vs. COMELEC [576 SCRA 290 (2008)]

FACTS:
On October 10, 2006, Cagayan de Oro’s then Congressman Constantino G. Jaraula filed and sponsored
House Bill No. 5859: An Act Providing for the Apportionment of the Lone Legislative District of the
City of Cagayan De Oro or RA No. 9371. It increased Cagayan de Oro’s legislative district from one to
two. For the election of May 2007, CDO’s voters would be classified as belonging to either the first or the
second district, depending on their place of residence. On March 13, 2007, COMELEC promulgated a
resolution implementing the said act. Bagabuyo filed a petition at the Supreme Court asking for the
nullification of RA 9371 and Resolution No. 7837 on constitutional grounds. Petitioner argued that
COMELEC cannot implement a law without the commencement of a plebiscite which is indispensable
for the division and conversion of a local govt. unit.

ISSUE: Whether or not the law, of which pertains to the legislative apportionment of a city, involve the
division and conversion of a local government unit, necessitating a plebiscite

DECISION: Dismissed

RATIO DECIDENDI: The Court upheld respondent’s arguments saying that such law only increased the
representation of CDO in the House of Representatives and Sangguniang Panglungsod. Creation,
division, merger, abolition, and alteration of boundaries under Art. X Sec. 10 requires the commencement
of a plebiscite , while legislative apportionment or reapportionment under Art. VI, Sec.5 need not. There
was also no change in CDO’s territory, population, income and classfication
5) Atong Paglaum, Inc. vs. COMELEC (G.R. No. 203766, April 2, 2013)
FACTS:
52 party-list groups and organizations filed separate petitions totaling 54 with the Supreme Court (SC) in
an effort to reverse various resolutions by the Commission on Elections (Comelec) disqualifying them
from the May 2013 party-list race. The Comelec, in its assailed resolutions issued in October, November
and December of 2012, ruled, among others, that these party-list groups and organizations failed to
represent a marginalized and underrepresented sector, their nominees do not come from a marginalized
and underrepresented sector, and/or some of the organizations or groups are not truly representative of the
sector they intend to represent in Congress.

Petitioners argued that the COMELEC committed grave abuse of discretion amounting to lack or excess
of jurisdiction in disqualifying petitioners from participating in the 13 May 2013 party-list elections,
either by denial of their new petitions for registration under the party-list system, or by cancellation of
their existing registration and accreditation as party-list organizations; andsecond, whether the criteria for
participating in the party-list system laid down inAng Bagong Bayani and Barangay Association for
National Advancement and Transparency v. Commission on Elections(BANAT) should be applied by the
COMELEC in the coming 13 May 2013 party-list elections.

ISSUE: Whether or not the COMELEC committed grave abuse of discretion?

HELD: No. The COMELEC merely followed the guidelines set in the cases of Ang Bagong Bayani and
BANAT. However, the Supreme Court remanded the cases back to the COMELEC as the Supreme Court
now provides for new guidelines which abandoned some principles established in the two aforestated
cases.

Commissioner Christian S. Monsod, the main sponsor of the party-list system, stressed that "the party-list
system is not synonymous with that of the sectoral representation." Indisputably, the framers of the 1987
Constitution intended the party-list system to include not only sectoral parties but also non-sectoral
parties. The framers intended the sectoral parties to constitute a part, but not the entirety, of the party-list
system.As explained by Commissioner Wilfredo Villacorta, political parties can participate in the party-
list system "For as long as they field candidates who come from the different marginalized sectors that we
shall designate in this Constitution."

Republic Act No. 7941 or the Party-List System Act is the law that implements the party-list system
prescribed in the Constitution.

Section 3(a) of R.A. No. 7941 defines a "party" as"either a political party or a sectoral partyor a coalition
of parties." Clearly, a political party is different from a sectoral party. Section 3(c) of R.A. No. 7941
further provides that a"political partyrefers to anorganized group of citizens advocating an ideology or
platform, principles and policies for the general conduct of government."On the other hand, Section 3(d)
of R.A. No. 7941 provides that a "sectoral partyrefers to an organized group of citizens belonging to any
of the sectors enumerated in Section 5 hereofwhose principal advocacy pertains to the special interest and
concerns of their sector."R.A. No. 7941 provides different definitions for a political and a sectoral party.
Obviously, they are separate and distinct from each other.

Under the party-list system, an ideology-based or cause-oriented political party is clearly different from a
sectoral party. A political party need not be organized as a sectoral party and need not represent any
particular sector. There is no requirement in R.A. No. 7941 that a national or regional political party must
represent a "marginalized and underrepresented" sector. It is sufficient that the political party consists of
citizens who advocate the same ideology or platform, or the same governance principles and
policies,regardless of their economic status as citizens.

The COMELEC excluded from participating in the 13 May 2013 party-list elections those that did not
satisfy these two criteria: (1) all national, regional, and sectoral groups or organizations must represent the
"marginalized and underrepresented" sectors, and (2) all nominees must belong to the "marginalized and
underrepresented" sector they represent. Petitioners may have been disqualified by the COMELEC
because as political or regional parties they are not organized along sectoral lines and do not represent the
"marginalized and underrepresented."

Also, petitioners' nominees who do not belong to the sectors they represent may have been disqualified,
although they may have a track record of advocacy for their sectors. Likewise, nominees of non-sectoral
parties may have been disqualified because they do not belong to any sector. Moreover, a party may have
been disqualified because one or more of its nominees failed to qualify, even if the party has at least one
remaining qualified nominee.

In determining who may participate in the coming 13 May 2013 and subsequent party-list elections, the
COMELEC shall adhere to the following parameters:

1. Three different groups may participate in the party-list system: (1) national parties or organizations, (2)
regional parties or organizations, and (3) sectoral parties or organizations.

2. National parties or organizations and regional parties or organizations do not need to organize along
sectoral lines and do not need to represent any "marginalized and underrepresented" sector.

3. Political parties can participate in party-list elections provided they register under the party-list system
and do not field candidates in legislative district elections. A political party, whether major or not, that
fields candidates in legislative district elections can participate in party-list elections only through its
sectoral wing that can separately register under the party-list system. The sectoral wing is by itself an
independent sectoral party, and is linked to a political party through a coalition.

4. Sectoral parties or organizations may either be "marginalized and underrepresented" or

lacking in "well-defined political constituencies." It is enough that their principal advocacy
pertains to the special interest and concerns of their sector. The sectors that are "marginalized
and underrepresented" include labor, peasant, fisherfolk, urban poor, indigenous cultural
communities, handicapped, veterans, and overseas workers. The sectors that lack "well-
defined political constituencies" include professionals, the elderly, women, and the youth.
5. A majority of the members of sectoral parties or organizations that represent the "marginalized and
underrepresented" must belong to the "marginalized and underrepresented" sector they represent.
Similarly, a majority of the members of sectoral parties or organizations that lack "well-defined political
constituencies" must belong to the sector they represent. The nominees of sectoral parties or organizations
that represent the "marginalized and underrepresented," or that represent those who lack "well-defined
political constituencies," either must belong to their respective sectors, or must have a track record of
advocacy for their respective sectors. The nominees of national and regional parties or organizations must
be bona-fide members of such parties or organizations.

6. National, regional, and sectoral parties or organizations shall not be disqualified if some of their
nominees are disqualified, provided that they have at least one nominee who remains qualified.

This Court is sworn to uphold the 1987 Constitution, apply its provisions faithfully, and desist from
engaging in socio-economic or political experimentations contrary to what the Constitution has ordained.
Judicial power does not include the power to re-write the Constitution. Thus, the present petitions should
be remanded to the COMELEC not because the COMELEC committed grave abuse of discretion in
disqualifying petitioners, but because petitioners may now possibly qualify to participate in the coming 13
May 2013 party-list elections under the new parameters prescribed by this Court. Petitions Granted.

6) Ang Ladlad LGBT Party vs. COMELEC (G.R. No. 190582, April 8, 2010)
FACTS:
Ang Ladlad is an organization composed of men and women who identify themselves as lesbians, gays,
bisexuals, or trans-gendered individuals (LGBTs). Incorporated in 2003, Ang Ladlad first applied for
registration with the COMELEC in 2006. The application for accreditation was denied on the ground that
the organization had no substantial membership base. On August 17, 2009, Ang Ladlad again filed a
Petition for registration with the COMELEC.

Before the COMELEC, petitioner argued that the LGBT community is a marginalized and under-
represented sector that is particularly disadvantaged because of their sexual orientation and gender
identity; that LGBTs are victims of exclusion, discrimination, and violence; that because of negative
societal attitudes, LGBTs are constrained to hide their sexual orientation; and that Ang Ladlad complied
with the 8-point guidelines enunciated by this Court in Ang Bagong Bayani-OFW Labor Party v.
Commission on Elections. Ang Ladlad laid out its national membership base consisting of individual
members and organizational supporters, and outlined its platform of governance.

On November 11, 2009, after admitting the petitioners evidence, the COMELEC (Second Division)
dismissed the Petition on moral grounds, stating that: This Petition is dismissible on moral grounds.
Petitioner defines the Filipino Lesbian, Gay, Bisexual and Transgender (LGBT) Community, thus a
marginalized and under-represented sector that is particularly disadvantaged because of their sexual
orientation and gender identity. and proceeded to define sexual orientation as that which refers to a
persons capacity for profound emotional, affectional and sexual attraction to, and intimate and sexual
relations with, individuals of a different gender, of the same gender, or more than one gender.

ANG LADLAD collides with Article 695 of the Civil Code which defines nuisance as Any act, omission,
establishment, business, condition of property, or anything else which (3) shocks, defies; or
disregardsdecency or morality.

It also collides with Article 1306 of the Civil Code: The contracting parties may establish such
stipulations, clauses, terms and conditions as they may deem convenient, provided they are not contrary
to law, morals, good customs, public order or public policy. Art 1409 of the Civil Code provides that
Contracts whose cause, object or purpose is contrary to law, morals, good customs, public order or public
policy are inexistent and void from the beginning.

Finally to safeguard the morality of the Filipino community, the Revised Penal Code, as amended,
penalizes Immoral doctrines, obscene publications and exhibitions and indecent shows as follows:

Art. 201. Immoral doctrines, obscene publications and exhibitions, and indecent shows.

When Ang Ladlad sought reconsideration, three commissioners voted to overturn the First Assailed
Resolution (Commissioners Gregorio Y. Larrazabal, Rene V. Sarmiento, and Armando Velasco), while
three commissioners voted to deny Ang Ladlads Motion for Reconsideration (Commissioners Nicodemo
T. Ferrer, Lucenito N. Tagle, and Elias R. Yusoph). The COMELEC Chairman, breaking the tie and
speaking for the majority in his Separate Opinion, upheld the First Assailed Resolution, stating that:
Ladlad is applying for accreditation as a sectoral party in the party-list system. Even assuming that it has
properly proven its under-representation and marginalization, it cannot be said that Ladlads expressed
sexual orientations per se would benefit the nation as a whole.

Thus, even if societys understanding, tolerance, and acceptance of LGBTs is elevated, there can be no
denying that Ladlad constituencies are still males and females, and they will remain either male or female
protected by the same Bill of Rights that applies to all citizens alike.

There is no question about not imposing on Ladlad Christian or Muslim religious practices. Neither is
there any attempt to any particular religious groups moral rules on Ladlad. Rather, what are being adopted
as moral parameters and precepts are generally accepted public morals. They are possibly religious-based,
but as a society, the Philippines cannot ignore its more than 500 years of Muslim and Christian
upbringing, such that some moral precepts espoused by said religions have sipped [sic] into society and
these are not publicly accepted moral norms.

On January 4, 2010, Ang Ladlad filed this Petition, praying that the Court annul the Assailed Resolutions
and direct the COMELEC to grant Ang Ladlads application for accreditation. Ang Ladlad also sought the
issuance ex parte of a preliminary mandatory injunction against the COMELEC, which had previously
announced that it would begin printing the final ballots for the May 2010 elections by January 25, 2010.

ISSUE: Should Ang Ladlad's application for accreditation be granted?

HELD: The lesbian, gay, bisexual, and transgender have the same interest in participating in the party-list
system on the same basis as other political parties similarly situated. State intrusion in this case is equally
burdensome. Hence, laws of general application should apply with equal force to LGBTs, and they
deserve to participate in the party-list system on the same basis as other marginalized and under-
represented sectors.

It bears stressing that our finding that COMELECs act of differentiating LGBTs from heterosexuals
insofar as the party-list system is concerned does not imply that any other law distinguishing between
heterosexuals and homosexuals under different circumstances would similarly fail. The Court disagree
with the OSGs position that homosexuals are a class in themselves for the purposes of the equal
protection clause. It should not single out homosexuals as a separate class meriting special or
differentiated treatment. We have not received sufficient evidence to this effect, and it is simply
unnecessary to make such a ruling today. Petitioner itself has merely demanded that it be recognized
under the same basis as all other groups similarly situated, and that the COMELEC made "an unwarranted
and impermissible classification not justified by the circumstances of the case."

Under our system of laws, every group has the right to promote its agenda and attempt to persuade society
of the validity of its position through normal democratic means. It is in the public square that deeply held
convictions and differing opinions should be distilled and deliberated upon.

In a democracy, this common agreement on political and moral ideas is distilled in the public square.
Where citizens are free, every opinion, every prejudice, every aspiration, and every moral discernment
has access to the public square where people deliberate the order of their life together. Citizens are the
bearers of opinion, including opinion shaped by, or espousing religious belief, and these citizens have
equal access to the public square. In this representative democracy, the state is prohibited from
determining which convictions and moral judgments may be proposed for public deliberation. Through a
constitutionally designed process, the people deliberate and decide. Majority rule is a necessary principle
in this democratic governance. Thus, when public deliberation on moral judgments is finally crystallized
into law, the laws will largely reflect the beliefs and preferences of the majority, i.e., the mainstream or
median groups. Nevertheless, in the very act of adopting and accepting a constitution and the limits it
specifies including protection of religious freedom "not only for a minority, however small not only for a
majority, however large but for each of us" the majority imposes upon itself a self-denying ordinance. It
promises not to do what it otherwise could do: to ride roughshod over the dissenting minorities.

Freedom of expression constitutes one of the essential foundations of a democratic society, and this
freedom applies not only to those that are favorably received but also to those that offend, shock, or
disturb. Any restriction imposed in this sphere must be proportionate to the legitimate aim pursued.
Absent any compelling state interest, it is not for the COMELEC or this Court to impose its views on the
populace. Otherwise stated, the COMELEC is certainly not free to interfere with speech for no better
reason than promoting an approved message or discouraging a disfavored one.

All persons are equal before the law and are entitled without any discrimination to the equal protection of
the law. In this respect, the law shall prohibit any discrimination and guarantee to all persons equal and
effective protection against discrimination on any ground such as race, colour, sex, language, religion,
political or other opinion, national or social origin, property, birth or other status.

In this context, the principle of non-discrimination requires that laws of general application relating to
elections be applied equally to all persons, regardless of sexual orientation. Although sexual orientation is
not specifically enumerated as a status or ratio for discrimination in Article 26 of the ICCPR, the ICCPR
Human Rights Committee has opined that the reference to "sex" in Article 26 should be construed to
include "sexual orientation." Additionally, a variety of United Nations bodies have declared
discrimination on the basis of sexual orientation to be prohibited under various international agreements.

7) Philippine Guardians Brotherhood, Inc. vs. COMELEC ( G.R. No. 190529, April 29, 2010)
FACTS:
For the upcoming May 2010 elections, the COMELECen banc issued on October 13, 2009 Resolution
No. 8679 deleting several party-list groups or organizations from the list of registered national, regional
or sectoral parties, organizations or coalitions.Among the party-list organizations affected was PGBI; it
was delisted because it failed to get 2% of the votes cast in 2004 and it did not participate in the 2007
elections.PGBI filed its Opposition to Resolution No. 8679, but likewise sought, through its pleading, the
admission ad cautelam of its petition for accreditation as a party-list organization under the Party-List
System Act. The COMELEC denied PGBIs motion/opposition for lack of merit.

ISSUE: Whether or not there is legal basis for delisting PGBI.

HELD: COMELEC's decision is annulled.

POLITICAL LAW: delisting of any national, regional or sectoral party

The law is clear the COMELEC may motu proprio or upon verified complaint of any interested party,
remove or cancel, after due notice and hearing, the registration of any national, regional or sectoral party,
organization or coalition if it: (a)fails to participate in the last two (2) preceding elections;or(b)fails to
obtain at least two per centum (2%) of the votes cast under the party-list system in the two (2) preceding
elections for the constituency in which it has registered. The word or is a disjunctive term signifying
disassociation and independence of one thing from the other things enumerated; it should, as a rule, be
construed in the sense in which it ordinarily implies,as a disjunctive word. Thus, the plain, clear and
unmistakable language of the law provides for two (2) separate reasons for delisting.

To reiterate, (a) Section 6(8) of RA 7941 provides for two separate grounds for delisting; these grounds
cannot be mixed or combined to support delisting; and (b) the disqualification for failure to garner 2%
party-list votes in two preceding elections should now be understood to mean failure to qualify for a
party-list seat in two preceding elections for the constituency in which it has registered.This is how
Section 6(8) of RA 7941 should be understood and applied.

PGBIs situation a party list group or organization that failed to garner 2% in a prior election and
immediately thereafter did not participate in the preceding election is something that is not covered by
Section 6(8) of RA 7941.From this perspective, it may be an unintended gap in the law and as such is a
matter for Congress to address.The Court cannot and do not address matters over which full discretionary
authority is given by the Constitution to the legislature; to do so will offend the principle of separation of
powers.If a gap indeed exists, then the present case should bring this concern to the legislatures notice.

On the due process issue, PGBI's right to due process was not violated for PGBI was given an opportunity
to seek, as it did seek, a reconsideration of Resolution No. 8679.The essence of due process is simply the
opportunity to be heard; as applied to administrative proceedings, due process is the opportunity to
explain ones side or the opportunity to seek a reconsideration of the action or ruling complained of.A
formal or trial-type hearing is not at all times and in all instances essential.The requirement is satisfied
where the parties are afforded fair and reasonable opportunity to explain their side of the controversy at
hand. What is frowned upon is absolute lack of notice and hearing. PGBI was not denied due process.In
any case, given the result of this Resolution, PGBI has no longer any cause for complaint on due process
grounds.

The petition for review is GRANTED.

8) Palparan vs. HRET (G.R. No. 189506, February 11, 2010)

FACTS:
Petitioner Daryl Grace J. Abayon is the first nominee of the Aangat Tayo party-list organization that won
a seat in the House of Representatives during the 2007 elections.

Respondents Perfecto C. Lucaban, Jr., Ronyl S. Dela Cruz, and Agustin C. Doroga, all registered voters,
filed a petition for quo warranto with respondent HRET against Aangat Tayo and its nominee, petitioner
Abayon, alleging that Aangat Tayo was not eligible for a party-list seat in the House of Representatives,
since it did not represent the marginalized and underrepresented sectors.

Petitioner Abayon countered that the COMELEC had already confirmed the status of Aangat Tayo as a
national multi-sectoral party-list organization
Share
CASE DIGEST: ABAYON VS. HRET (G.R. NO. 189466; FEBRUARY 11, 2010)

CASE DIGEST: DARYL GRACE J. ABAYON,Petitioner, v. THE HONORABLE HOUSE OF

REPRESENTATIVES ELECTORAL TRIBUNAL, PERFECTO C. LUCABAN, JR., RONYL S. DE LA
CRUZ and AGUSTIN C. DOROGA, Respondents. G.R. No. 189466; February 11, 2010.

FACTS: Petitioner Daryl Grace J. Abayon is the first nominee of the Aangat Tayo party-list organization
that won a seat in the House of Representatives during the 2007 elections.

Respondents Perfecto C. Lucaban, Jr., Ronyl S. Dela Cruz, and Agustin C. Doroga, all registered voters,
filed a petition for quo warranto with respondent HRET against Aangat Tayo and its nominee, petitioner
Abayon, alleging that Aangat Tayo was not eligible for a party-list seat in the House of Representatives,
since it did not represent the marginalized and underrepresented sectors.
Petitioner Abayon countered that the COMELEC had already confirmed the status of Aangat Tayo as a
national multi-sectoral party-list organization representing the workers, woelecmen, youth, urban poor,
and elderly and that she belonged to the women sector.

Finally, petitioner Abayon pointed out that respondent HRET had no jurisdiction over the petition for quo
warranto since respondent Lucaban and the others with him collaterally attacked the registration of
Aangat Tayo as a party-list organization, a matter that fell within the jurisdiction of the COMELEC.

On July 16, 2009 respondent HRET issued an order, dismissing the petition as against Aangat Tayo but
upholding its jurisdiction over the qualifications of petitioner Abayon. The latter moved for
reconsideration but the HRET denied the same on prompting Abayon to file the present petition for
special civil action of certiorari.

In G.R. 189506, petitioner Jovito S. Palparan, Jr. is the first nominee of the Bantay party-list group that
won a seat in the 2007 elections for the members of the House of Representatives. Respondents Reynaldo
Lesaca, Jr., Cristina Palabay, Renato M. Reyes, Jr., Erlinda Cadapan, Antonio Flores, and Joselito Ustarez
are members of some other party-list groups.

Shortly after the elections, respondent Lesaca and the others with him filed with respondent HRET a
petition for quo warranto against Bantay and its nominee, petitioner Palparan, alleging that Palparan was
ineligible to sit in the House of Representatives as party-list nominee because he did not belong to the
marginalized and underrepresented sectors that Bantay represented, namely, the victims of communist
rebels, Civilian Armed Forces Geographical Units (CAFGUs), former rebels, and security guards. Lesaca
and the others said that Palparan committed gross human rights violations against marginalized and
underrepresented sectors and organizations.

Petitioner Palparan countered that the HRET had no jurisdiction over his person since it was actually the
party-list Bantay, not he, that was elected to and assumed membership in the House of Representatives.
Palparan claimed that he was just Bantays nominee. Consequently, any question involving his eligibility
as first nominee was an internal concern of Bantay. Such question must be brought, he said, before that
party-list group, not before the HRET.

Respondent HRET issued an order dismissing the petition against Bantay for the reason that the issue of
the ineligibility or qualification of the party-list group fell within the jurisdiction of the COMELEC
pursuant to the Party-List System Act.

ISSUE: Does respondent HRET have jurisdiction over the question of qualifications of petitioners
Abayon and Palparan as nominees of Aangat Tayo and Bantay party-list organizations, respectively, who
took the seats at the House of Representatives that such organizations won in the 2007 elections?

HELD: HRET has jurisdiction. As this Court also held in Bantay Republic Act or BA-RA 7941 v.
Commission on Elections, a party-list representative is in every sense "an elected member of the House of
Representatives." Although the vote cast in a party-list election is a vote for a party, such vote, in the end,
would be a vote for its nominees, who, in appropriate cases, would eventually sit in the House of
Representatives.

Both the Constitution and the Party-List System Act set the qualifications and grounds for disqualification
of party-list nominees.
In the cases before the Court, those who challenged the qualifications of petitioners Abayon and Palparan
claim that the two do not belong to the marginalized and underrepresented sectors that they ought to
represent. The Party-List System Act provides that a nominee must be a "bona fide member of the party
or organization which he seeks to represent."

It is for the HRET to interpret the meaning of this particular qualification of a nominee the need for him
or her to be a bona fide member or a representative of his party-list organization in the context of the facts
that characterize petitioners Abayon and Palparans relation to Aangat Tayo and Bantay, respectively, and
the marginalized and underrepresented interests that they presumably embody.
Parenthetically, although the Party-List System Act does not so state, the COMELEC seems to believe,
when it resolved the challenge to petitioner Abayon, that it has the power to do so as an incident of its
authority to approve the registration of party-list organizations. But the Court need not resolve this
question since it is not raised here and has not been argued by the parties.

What is inevitable is that Section 17, Article VI of the Constitution provides that the HRET shall be the
sole judge of all contests relating to, among other things, the qualifications of the members of the House
of Representatives. Since, as pointed out above, party-list nominees are "elected members" of the House
of Representatives no less than the district representatives are, the HRET has jurisdiction to hear and pass
upon their qualifications. By analogy with the cases of district representatives, once the party or
organization of the party-list nominee has been proclaimed and the nominee has taken his oath and
assumed office as member of the House of Representatives, the COMELEC's jurisdiction over election
contests relating to his qualifications ends and the HRET's own jurisdiction begins.

Hence, respondent HRET did not gravely abuse its discretion when it dismissed the petitions for quo
warranto against Aangat Tayo party-list and Bantay party-list but upheld its jurisdiction over the question
of the qualifications of petitioners Abayon and Palparan.

9) Aldana vs. COMELEC (G.R. No. 188078, January 25, 2010)

FACTS:
This case is an original action for Prohibition to declareunconstitutional, R.A. 9591 which creates a
legislative district for the City of Malolos, Bulacan. Allegedly, the R.A. violates the minimum population
requirement for the creation of a legislative district in a city. Before the May 1, 2009, the province of
Bulacan was represented in Congress through 4 legislative districts. Before the passage of the Act through
House Bill 3162 (later converted to House Bill 3693) and Senate Bill 1986, Malolos City had a
population of 223, 069 in 2007.

House Bill 3693 cites the undated Certification, as requested to be issued to Mayor Domingo (then Mayor
of Malolos), by Region III Director Miranda of NSO that the population of Malolos will be as projected,
254,030 by the year 2010.

Petitioners contended that R.A. 9591 is unconstitutional for failing to meet the minimum population
threshold of 250,000 for a city to meritrepresentative in Congress.

OSG contended that Congress use of projected population is non-justiciable as it involves a determination
on the wisdom of the standard adopted by the legislature to determine compliance with constitutional
requirement.

ISSUE:
RA 9591 is unconstitutional for failing to meet the minimum population threshold of 250,000 for a city to
merit representation in Congress as provided under Section 5(3), Article VI of the 1987 Constitution and
Section 3 of the Ordinance .
RULING:
RA 9591 is unconstitutional. The 1987 Constitution requires that for a city to have a legislative district,
the city must have a population of at least two hundred fifty thousand.[5] The only issue here is whether
the City of Malolos has a population of at least 250,000, whether actual or projected, for the purpose of
creating a legislative district for the City of Malolos in time for the 10 May 2010 elections. If not, then
RA 9591 creating a legislative district in the City of Malolos is unconstitutional.

The Certification of Regional Director Miranda, which is based on demographic projections, is without
legal effect because Regional Director Miranda has no basis and no authority to issue the Certification.
The Certification is also void on its face because based on its own growth rate assumption, the population
of Malolos will be less than 250,000 in the year 2010. In addition, intercensal demographic projections
cannot be made for the entire year. In any event, a city whose population has increased to 250,000 is
entitled to have a legislative district only in the immediately following election after the attainment of the
250,000 population.

The Certification of Regional Director Miranda does not state that the demographic projections he
certified have been declared official by the NSCB. The records of this case do not also show that the
Certification of Regional Director Miranda is based on demographic projections declared official by the
NSCB. The Certification, which states that the population of Malolos will be 254,030 by the year 2010,
violates the requirement that intercensal demographic projections shall be as of the middle of every year.
In addition, there is no showing that Regional Director Miranda has been designated by the NSO
Administrator as a certifying officer for demographic projections in Region III. In the absence of such
official designation, only the certification of the NSO Administrator can be given credence by this Court.

Any population projection forming the basis for the creation of a legislative district must be based on an
official and credible source. That is why the OSG cited Executive Order No. 135, otherwise the
population projection would be unreliable or speculative.

Section 3 of the Ordinance appended to the 1987 Constitution provides:

Any province that may be created, or any city whose population may hereafter increase to more than two
hundred fifty thousand shall be entitled in the immediately following election to at least one Member or
such number of members as it may be entitled to on the basis of the number of its inhabitants and
according to the standards set forth in paragraph (3), Section 5 of Article VI of the Constitution. xxx.
(Emphasis supplied)

10) Aquino vs. COMELEC (G.R. No. 189793, April 2, 2010)

FACTS:
RA 9716 was signed into law by PGMA on October 2009. This law created an additional legislative
district for the Province of Camarines Sur by reconfiguring the existing 1st and 2nd districts of CamSur.

Aquino and Robredo contend that the reapportionment runs foul of the constitutional standard that
requires minimum population of 250k for a creation of legislative district (the new 1st and 2nd district in
RA 9716 has population less than 250k).

Respondents, represented by Office of Solicitor General seek to dismiss the petition based on: On
procedural matters, the respondents argue that the petitioners are guilty of two (2) fatal technical defects:
first, petitioners committed an error in choosing to assail the constitutionality of Republic Act No. 9716
via the remedy of Certiorari and Prohibition under Rule 65 of the Rules of Court; and second, the
petitioners have no locus standi to question the constitutionality of Republic Act No. 9716.

On substantive matters, the respondents call attention to an apparent distinction between cities and
provinces drawn by Section 5(3), Article VI of the 1987 Constitution. The respondents concede the
existence of a 250,000 population condition, but argue that a plain and simple reading of the questioned
provision will show that the same has no application with respect to the creation of legislative districts in
provinces.13 Rather, the 250,000 minimum population is only a requirement for the creation of a
legislative district in a city.

ISSUE:
Is the population of 250,000 an indispensable constitutional requirement for the creation of a new
legislative district in a province?

RULING:
Yes, it is an indispensable constitutional requirement. The second sentence of Section 5(3), Article VI of
the Constitution, succinctly provides: "Each city with a population of at least two hundred fifty thousand,
or each province, shall have at least one representative."

The provision draws a plain and clear distinction between the entitlement of a city to a district on one
hand, and the entitlement of a province to a district on the other. For while a province is entitled to at least
a representative, with nothing mentioned about population, a city must first meet a population minimum
of 250,000 in order to be similarly entitled.

The use by the subject provision of a comma to separate the phrase "each city with a population of at least
two hundred fifty thousand" from the phrase "or each province" point to no other conclusion than that the
250,000 minimum population is only required for a city, but not for a province.

Plainly read, Section 5(3) of the Constitution requires a250,000 minimum population only for a city to be
entitled to a representative, but not so for a province. DISMISSED.

11) BANAT vs. COMELEC (G.R. No. 179271, April 21, 2009)

12) Bantay Republic Act or BA-RA7941 vs. COMELEC (G.R. No. 177271, May 4, 2007)
13) Veterans Federation Party vs. COMELEC (G.R. No. 136781, October 6, 2000)
14) Ang Bagong Bayani-OFW Labor Party vs. COMELEC (G.R. No. 147589, June 26, 2001)
15) Mariano, Jr. vs. COMELEC (G.R. 118577, March 7, 1995)
16) Montejo vs. COMELEC (G.R. No. 118702, March 16, 1995)
17) Tobias vs. Abalos (G.R. No. 114783, December 8, 1994)
18) R.A. No. 7941 (Party List System)
Section 6
17) Caballero vs. COMELEC (G.R. No. 209835, September 22, 2015)
18) Romualdez-Marcos vs. COMELEC (G.R. No. 119976, September 18, 1995)
19) Aquino vs. COMELEC (G.R. No. 120265, September 18, 1995)
20) Frivaldo vs. COMELEC (G.R. No. 120295, June 28, 1996)
21) Co vs. House of Representatives Electoral Tribunal (G.R. Nos. 92191-92, July 30, 1991)
Section 7
22) Dimaporo vs. Mitra (G.R. No. 96859, October 15, 1991)
Section 8
23) Republic Act 6645
Section 11
>Privilege from Arrest:
- the privilege did not include immunity from arrest arising from an act or omission punishable by
law, it covered only immunity from civil arrests.
- on offenses punishable by not more than six (6) years
- the immunity applies for as long as Congress is in session, whether or not the legislator involved
is actually attending to it.
- they may be arrested, even when the House is in session, for crimes punishable by a penalty of
more than six months
>Freedom of Speech and Debate

24) Osmena vs. Pendatun (G.R. No. L-17144, October 28, 1960)
25) Pobre vs. Defensor-Santiago (A.C. No. 7399, August 25, 2009)
26) Jimenez vs. Cabangbang (G.R. No. 15905, August 3, 1966)
27) People vs. Jalosjos (G.R. No. 132875, February 3, 2000)
Section 13
28) Liban vs. Gordon [G.R. No. 175352 (2009)]
29) Zandueta vs. Dela Costa (G.R. No. 46267, November 28, 1938)
30) Adaza vs. Pacana [135 SCRA 431 (1985)]
Section 14
31) Puyat vs. De Guzman (G.R. No. 51122, March 25, 1982)
Section 16
32) Casco Philippine Chemical Co. vs. Gimenez (G.R. No. L-17931, February 28, 1963)
33) Osmeña vs. Pendatun (G.R. No. L-17144, October 28, 1960)
34) U.S. vs. Pons (G.R. No. 11530, August 12, 1916)
35) Arroyo vs. De Venecia (G.R. No. 127255, August 14, 1997)
36) Avelino vs. Cuenco (G.R. No. L-2821, March 4, 1949)
37) Santiago vs. Guingona (G.R. No. 134577, November 18, 1998)
38) Philippine Judges Association vs. Prado (G.R. No. 105371, November 11, 1993)
39) Santiago vs. Sandiganbayan (G.R. No. 128055, April 18 2001)
40) De Venecia vs. Sandiganbayan (G.R. No. 130240, February 5, 2002)
41) Paredes, Jr. vs. Sandiganbayan (G.R. No. 118354, August 8, 1995)
Section 17
42) Poe-Llamanzares vs. COMELEC [G.R. No. 221697 (2016)]
43) Abayon vs. House of Representatives Electoral Tribunal (G.R. No. 189466 and 189506,
February 22, 2010)
44) Lico vs. COMELEC (G.R. No. 205505, September 29, 2015)
45) Tanada vs. House of Representatives Electoral Tribunal (G.R. No. 217012, March 1, 2016)
46) Duenas Jr. vs. HRET [G.R. No. 185401 (2009)]
47) Macalintal vs. Presidential Electoral Tribunal (G.R. No. 191618, Nov. 23, 20100
48) Pimentel vs. House of Representatives Electoral Tribunal (G.R. No. 141489, November 29,
2002)
49) Robles vs. House of Representatives Electoral Tribunal (G.R. No. 86647, February 5, 1990)
50) Palparan vs. House of Representatives Electoral Tribunal (G.R. No. 189506, February 11,
2010)
51) Abbas vs. Senate Electoral Tribunal (G.R. No. L-83767, October 27, 1988)
52) Angara vs. Electoral Commission (G.R. No. 45081, July 15, 1936)
53) Lazatin vs. Electoral Commission [8 SCRA 391 (1988)]
54) Chavez vs. COMELEC [211 SCRA 315 (1992)]
55) Ongsiako Reyes vs. COMELEC (G.R. No. 207264, June 25, 2013)
56) Bondoc vs. Pineda (G.R. No. 97710, September 26, 1991)
Section 18
57) Coseteng vs. Mitra (G.R. No. 86649, July 12, 1990)
58) Daza vs. Singson (G.R. No. 863344, December 21, 1989)
59) Guingona vs. Gonzales (G.R. No. 106971, October 20, 1992)