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Municipality of Makati to a Highly Urbanized City. Said law also created an additional legislative district.

The Mariano case


limited the application of the 250,000 minimum population requirement for cities only to its initial legislative district. While
Sec. 5(3), Art. VI requires a city to have a minimum population of 250,000 to be entitled to a representative, it does not have
to increase its population by another 250,000 to be entitled to an additional district.
Sec. 461 of LGC Requisites for Creation. (a) A province may be created if it has an average annual income, as certified by the
Department of Finance, of not less than P20M based on 1991 constant prices and either of the following requisites:
(i) a contiguous territory of at least 2,000 sq km, as certified by the Lands Management Bureau; OR
(ii) a population of not less than 250,000 inhabitants as certified by the National Statistics Office.
- the requirement of population is not an indispensable requirement, but is merely an alternative

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