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This document summarizes a Supreme Court case regarding the election of local government officials in Metro Manila under Republic Act 7166. The Court ruled that (1) Sangguniang Bayan members in Parañaque and other Metro Manila municipalities would be elected by district in the May 1992 elections, as these areas had been apportioned into two districts, and (2) Sangguniang Panlungsod members of single-district cities and Sangguniang Bayan members of municipalities outside Metro Manila would continue to be elected at-large in May 1992, but would transition to district-based elections starting in 1995 to fully implement the spirit of RA 7166.
This document summarizes a Supreme Court case regarding the election of local government officials in Metro Manila under Republic Act 7166. The Court ruled that (1) Sangguniang Bayan members in Parañaque and other Metro Manila municipalities would be elected by district in the May 1992 elections, as these areas had been apportioned into two districts, and (2) Sangguniang Panlungsod members of single-district cities and Sangguniang Bayan members of municipalities outside Metro Manila would continue to be elected at-large in May 1992, but would transition to district-based elections starting in 1995 to fully implement the spirit of RA 7166.
This document summarizes a Supreme Court case regarding the election of local government officials in Metro Manila under Republic Act 7166. The Court ruled that (1) Sangguniang Bayan members in Parañaque and other Metro Manila municipalities would be elected by district in the May 1992 elections, as these areas had been apportioned into two districts, and (2) Sangguniang Panlungsod members of single-district cities and Sangguniang Bayan members of municipalities outside Metro Manila would continue to be elected at-large in May 1992, but would transition to district-based elections starting in 1995 to fully implement the spirit of RA 7166.
May 6,1992 Bellosollo, J.: FAC TS On November 18, 1991, Congress passed RA 7166 “An Act providing for Synchronized National and Local Elections and for Electoral Reforms, Authorizing Appropriations therefore, and for other purposes. “
On November 20, 1991, COMELEC issued Resolution
No. 2313 and the subsequent resolutions in question.
Petitioner De Guia, filed with COMELEC a motion for
clarification of its Resolution No. 2313 on February 20, 1992. FAC TS COMELEC issued Resolution No. 2379 stating that its purpose in recommending to Congress the apportionment of Sangguniang Panglungsod and Bayan seats to reduce the number of candidates to be voted for.
Petitioner De Guia received the copy of the
Resolution but still filed an instant petition for reversal of the position of the respondent. ISSU E Whether the Members of the Sangguniang Bayan of Parañaque and other municipalities of Metro Manila enumerated therein, would be elected by district in the May 11, 1992 regular elections? RULI NG Yes. As stated in Par. (c) Sec. 3, Cities with 2 or more legislative districts (Manila, Cebu, Davao) shall continue to be elected by district, as well as the 13 Mun. of Metro Manila which have already been apportioned into 2 districts. RULI NG Par. (d) Sec. 3 of RA 7166 refers only to elective officials of the Sangguniang Panglungsod which are single district cities and Sangguniang Bayan for Municipalities outside Metro Manila, which will remain to be elected at large in the May 11, 1992 election. Spirit and purpose of the law
The reason for the promulgation of
R.A. 7166 is shown in the explanatory note of Senate Bill No. 1861, and that respondent COMELEC is cognizant of its legislative intent. Spirit and purpose of the law No law is ever enacted that is intended to be meaningless, much less inutile. We must therefore, as far as we can, divine its meaning, its significance, its reason for being. As it has oft been held, the key to open the door to what the legislature intended which is vaguely expressed in the language of a statute is its purpose or the reason which induced it to enact the statute. Spirit and purpose of the law The true import of Par. (d) is that Sangguniang Panlungsod of the single-district cities and the Sangguniang Bayan of the municipalities outside Metro Manila, which remained single-districts not having been ordered apportioned under Sec. 3 of R.A. 7166 will have to continue to be elected at large in the May 11, 1992, elections, although starting 1995 they shall all be elected by district to effect the full implementation of the letter and spirit of R.A. 7166. Thank you!