RAUL L. LAMBINO et al. vs COMELEC G.R. No.

174153

FACTS:
Petitioners Lambino Group gathered signatures for an initiative petition to change the 1987
Constitution by modifying the Legislative and Executive Department (sections 1-7 of Article 6
and sections1-4 of Article 7) and by adding Article 18 as “Transitory Provisions.” The proposed
changes will shift the present Bicameral-Presidential system to a Unicameral-Parliamentary
form of government. Allegedly, their petition had the support of 6,327,952 individuals
constituting at least 12% of all registered voters, with each legislative district represented by
at least 3% of its registered voters. COMELEC denied the petition due to lack of enabling law
governing initiative petitions and invoked the ruling on Santiago vs COMELEC that RA 6735 is
inadequate to supplement the initiative petitions.

ISSUES:
➢ Whether or not Lambino Group’s petition complies with constitutional provision on
Amendments of the Constitution through a people’s initiative.

➢ Whether or not the COMELEC committed grave abuse of discretion in denying due
course to Lambino’s petition.

RULING:
No. The court ruled that there is no merit to the petition which miserably failed to comply
with the basic requirements for conducting a people’s initiative. The draft of the proposed
constitutional amendment should be “ready and shown” to the people “before” they sign
such proposal. This means that the people must author and thus sign the entire proposal
which must be embodied in the petition. In this case, the majority of the 63 million people
who signed the signature sheets did not see the full text of the proposed changes before
signing and they were not apprised of the nature and effect of the proposed amendments.
Further, a people’s initiative can only propose amendments to the Constitution but the
Lambino Group’s proposal constituted a revision, not simply an amendment, because it
involved a change in the form of government, from presidential to parliamentary, and a shift
from the present bicameral to a unicameral legislature. The framers of the Constitution
intended and wrote that only Congress or a constitutional convention may propose revisions
to the Constitution. Hence, the people’s initiative as a mode to effect Lambino Group’s
amendments was invalid.

The Court ruled that no grave abuse of discretion could be attributed to COMELEC in
dismissing the Lambino Group’s Initiative. The COMELEC en banc merely followed the Court’s
unanimous ruling in Santiago vs. COMELEC. The Lambino Group’s claim that their initiative
is the “people’s voice” cannot override the specific modes of changing the Constitution as
prescribed in the Constitution itself. Otherwise, it becomes susceptible to manipulative
changes by political groups gathering signatures through false promises. Then, the
Constitution ceased to be the bedrock of the nation’s stability.

The Court dismissed the petition.

Case Digest submitted by: ROSETTE, EDITA JD 1-5