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G.R. No. 174153

Lambino vs COMELEC
Facts of the Case.
- On 15 February 2006, the of this case started to gather signatures for an initiative
petition to change the current constitution of the Philippines, which is the 1987
constitution. The petitioners ended up gathering 6,327,952, which complied with
the 12% per centum of all registered with at least 3% of each of the legislative
district representatives which was claimed to have been verified by the
COMELEC. The Petitioners cause was to change the 1987 constitution,
specifically the provisions of Sections 1-7 of Article VI (Legislative Department)4
and Sections 1-4 of Article VII (Executive Department) and by adding Article
XVIII entitled “Transitory Provisions.” In changing these provisions, they are
praying to shift the congressional structure from a bicameral-presidential system
into a unilateral-parlimentary government arrangement. Everything was running
smoothly until 30 August 2006 when the Lambino group, the petitioners, decided
to file the amendment petition alongside the COMELEC and proposed the
amendment plan. COMELEC afterwards denied the petition citing Santiago v.
COMELEC and declared RA 6735 insufficient to implement the initiative
stipulation on proposals to amend the specified part of the 1987 Constitution.
Issues.
- Whether the Lambino Group’s petition complies with Section 2, Article XVII of
the Constitution on amendments to the Constitution through people’s initiative.
- Whether this Court should revisit its ruling in Santiago declaring RA 6735 in
order to move forward with the case.
Decisions (Holdings)
- No, the petition does not comply with Section 2, Article XVII of the Constitution
because the signatures which the petitioners claimed to have did not contain the
signatures on the proposal itself, therefore dismissing their petition.
- The courts do not necessarily need to revisit the case of Santiago vs. COMELEC
due to the fact that revisiting it will not change the outcome of the case and is
therefore irrelevant to the petition. The court therefore shall disregard this
proposal immediately.
Reasoning (Rationale)
- The petitioner’s cause to amend the constitution via people’s initiative was not
compliant to Section 2, Article XVII by not having the official petition contain the
signatures of the people. The petitioners merely submitted a separate file
containing the signatures, but because the petition itself does not contain the said
signatures of the people, it is deemed as an error to the system of amending via
people’s initiative which the framers intended to be compiled with. Because the
case was dismissed on the grounds that the petition was not conducted
accordingly, the proposal to revisit the case of Santiago vs. COMELEC is hereby

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deemed irrelevant to the case since its presence will not affect any change on the
decision of the court.