Sultan Usman Sarangani vs COMELEC

Doctrine:

Municipal Corporations; Local Governments; It is not impossible for a certain barangay not to actually
have inhabitants considering that people migrate; A barangay may officially exist on record and the fact
that nobody resides in the place does not result in its automatic cessation as a unit of local government.

Under the Local Government Code of 1991, the abolition of a local government unit (LGU) may be done
by Congress in the case of a province, city, municipality, or any other political subdivision. In the case of a
barangay, except in Metropolitan Manila area and in cultural communities, it may be done by the
Sangguniang Panlalawigan or Sangguniang Panglungsod concerned subject to the mandatory requirement
of a plebiscite conducted for the purpose in the political units affected.

Case:

This petition for certiorari under Rule 65 of the Rules of Court which seeks to nullify the Order issued by
the Commission on Elections [COMELEC, for brevity] dated June 29, 1998, finding Padian Torogan in
Madalum, Lanao Del Sur as “ghost precinct,”

Facts:

A petition for annulment of several precincts and annulment of book of voters in Madalum, Lanao Del Sur
was filed with the COMELEC by, among others, Hadji Oblais R. Omar thru counsel Atty. Nasib D. Yasin,
herein private respondents. Among the precincts sought to be annulled was Padian Torogan, subject
matter of the present petition for certiorari.

The incumbent mayor of Madalum, Lanao Del Sur, Usman T. Sarangani, herein petitioner, together with
other oppositors who were allegedly barangay chairmen of the twenty-three (23) barangays the “Books
of Voters” and precincts of which were sought to be annulled and abolished, respectively, filed an “Answer
in Opposition”3 which included the affidavits of the barangay chairmen of the affected precincts attesting
to the fact that the move to annul the book of voters and abolish the questioned election precincts were
for the purpose of diminishing the bailiwicks of the incumbent mayor of Madalum, Lanao del Sur.

After hearing and submission of formal offer of exhibits and memoranda by the parties, the COMELEC
issued an Order dated February 11, 1998, referring the case to its Law Department for appropriate
investigation.

An ocular inspection was conducted on the alleged ghost precincts yielding the following results

“It appears that in this area there are only two structures: One is a concrete house with no roof, and the
other is a wooden structure without walls and roof. This obviously mean that no single human being could
possibly reside in these two structures. “Also, it came out that the name Padian-Torogan means a
cemetery not a residential place. So this contradicts the records being brought by the COMELEC Team
from the Census saying that the area has 45 households with a total population of 285. (Ref. Municipal
census Report as of September 1, 1995).

The COMELEC issued the assailed Order finding “Padian Torogan as ghost precinct.

Issue:

Whether or not the respondent COMELEC committed grave abuse of discretion in declaring Padian-
Torogan as ghost precinct.

Held:

NO. It appears from the records that Padian Torogan is a barangay in Madalum, Lanao del Sur and it was
erroneous for the COMELEC to consider Padian-Torogan as a ghost precinct.

But, upon review of the records, the Court finds that the COMELEC had exerted efforts to investigate the
facts and verified that there were no public or private buildings in the said place, hence its conclusion that
there were no inhabitants. If there were no inhabitants, a fortiori, there can be no registered voters, or
the registered voters may have left the place. It is not impossible for a certain barangay not to actually
have inhabitants considering that people migrate. A barangay may officially exist on record and the fact
that nobody resides in the place does not result in its automatic cessation as a unit of local government.

Under the Local Government Code of 1991, the abolition of a local government unit (LGU) may be done
by Congress in the case of a province, city, municipality, or any other political subdivision. In the case of a
barangay, except in Metropolitan Manila area and in cultural communities, it may be done by the
Sangguniang Panlalawigan or Sangguniang Panglungsod concerned subject to the mandatory requirement
of a plebiscite conducted for the purpose in the political units affected.

The findings of the administrative agency cannot be reversed on appeal or certiorari particularly when no
significant facts and circumstances are shown to have been overlooked or disregarded which when
considered would have substantially affected the outcome of the case. The COMELEC has broad powers
to ascertain the true results of an election by means available to it.17 The assailed order having been
issued pursu-ant to COMELEC’s administrative powers and in the absence of any finding of grave abuse of
discretion in declaring a precinct as nonexistent, said order shall stand. Judicial interference is unnecessary
and uncalled for.

Salva vs Macalintal

Petitioners, as officials and residents of barangay San Rafael, Calaca, Batangas, filed a class suit against
the Sangguniang Panglalawigan of Batangas, Sangguniang Pam-bayan of Calaca, Batangas, and the
Commission on Elections (COMELEC)

Ordinance No. 053 declared the abolition of barangay San Rafael and its merger with barangay Dacanlao,
municipality of Calaca, Batangas and accordingly instructed the COMELEC to conduct the required
plebiscite as provided under Sections 9 and 10 of Republic Act No. 7160, otherwise known as the Local
Government Code of 1991. On the other hand, Resolution No. 3455 affirmed the effectivity of Ordinance
No. 05, thereby overriding the veto6 exercised by the governor of Batangas.

Ordinance No. 05 was vetoed by the governor of Batangas for being ultra vires, particularly, as it was not
shown that the essential requirements under Section 9, in relation to Section 7, of Republic Act No. 7160,
referring to the attestations or certifications of the Department of Finance (DOF), National Statistics Office
(NSO) and the Land Management Bureau of the Department of Environment and Natural Resources
(DENR), were obtained.

Simultaneous with the filing of the action before the trial court, petitioners also filed an ex parte motion
for the issuance of a temporary restraining order to enjoin respondents from enforcing Ordinance No. 05,
Resolution No. 345, and COMELEC Resolution No. 2987.

In an Order dated February 25, 1998, the trial court denied the ex parte motion for the issuance of a
temporary restraining order and/or preliminary injunction for lack of jurisdiction.

According to the trial court, the temporary restraining order/injunction sought by petitioners is directed
only to COMELEC Resolution No. 2987.

The trial court ruled that any petition or action questioning an act, resolution or decision of the COMELEC
must be brought before the Supreme Court.

Issue:

WHETHER OR NOT THE RESPONDENT COURT HAS JURISDICTION TO ENJOIN THE COMELEC FROM
IMPLEMENTING ITS RESOLUTION NO. 2987, SERIES OF 1998, WHICH PROVIDED FOR THE RULES AND
REGULATIONS FOR THE CONDUCT OF THE PLEBI-SCITE SCHEDULED ON FEBRUARY 28, 1998 TO DECIDE ON
THE ABOLITION OF BARANGAY SAN RAFAEL AND ITS MERGER WITH BARANGAY DACANLAO, CALACA,
BATANGAS, PENDING THE DETERMINATION OF CIVIL CASE NO. 3442 FOR THE ANNULMENT OF
ORDINANCE NO. 05, RESOLUTION NO. 345 AND COMELEC RESOLUTION NO. 2987.

Held:

Yes. We agree with the Solicitor General that “x x x. [t]he issuance of [COMELEC] Resolution No. 2987 is
thus a ministerial duty of the COMELEC that is enjoined by law and is part and parcel of its administrative
functions. It involves no exercise of discretionary authority on the part of respondent COME-LEC; let alone
an exercise of its adjudicatory or quasi-judicial power to hear and resolve controversies defining the rights
and duties of party-litigants, relative to the conduct of elections of public officers and the enforcement of
the election laws.” (Citation omitted.)

Briefly, COMELEC Resolution No. 2987 which provides for the rules and regulations governing the conduct
of the required plebiscite, was not issued pursuant to the COMELEC’s quasi-judicial functions but merely
as an incident of its inherent administrative functions over the conduct of plebiscites, thus, the said
resolution may not be deemed as a “final order” reviewable by certiorari by this Court. Any question
pertaining to the validity of said resolution may be well taken in an ordinary civil action before the trial
courts.
In the present case, petitioners are not contesting the exclusive authority of the COMELEC to enforce and
administer election laws.

League of Cities v. Comelec

Case:
These are consolidated petitions for prohibition with prayer for the issuance of a writ of preliminary
injunction or temporary restraining order filed by the League of Cities of the Philippines, City of Iloilo, City
of Calbayog, and Jerry P. Treñas assailing the constitutionality of the subject Cityhood Laws and enjoining
the Commission on Elections (COMELEC) and respondent municipalities from conducting plebiscites
pursuant to the Cityhood Laws.

Fact:
During the 11th Congress, Congress enacted into law 33 bills converting 33 municipalities into cities.
However, Congress did not act on bills converting 24 other municipalities into cities.
During the 12th Congress, Congress enacted into law Republic Act No. 9009 (RA 9009), which took effect
on 30 June 2001.

RA 9009 amended Section 450 of the Local Government Code by increasing the annual income
requirement for conversion of a municipality into a city from P20 million to P100 million. The rationale for
the amendment was to restrain, in the words of Senator Aquilino Pimentel, “the mad rush” of
municipalities to convert into cities solely to secure a larger share in the Internal Revenue Allotment
despite the fact that they are incapable of fiscal independence.

After the effectivity of RA 9009, the House of Representatives of the 12th Congress adopted Joint
Resolution No. 29, which sought to exempt from the P100 million income requirement in RA 9009 the 24
municipalities whose cityhood bills were not approved in the 11th Congress. However, the 12th Congress
ended without the Senate approving Joint Resolution No. 29.

During the 13th Congress, the House of Representatives re-adopted Joint Resolution No. 29 as Joint
Resolution No. 1 and forwarded it to the Senate for approval. However, the Senate again failed to approve
the Joint Resolution. Following the advice of Senator Aquilino Pimentel, 16 municipalities filed, through
their respective sponsors, individual cityhood bills. The 16 cityhood bills contained a common provision
exempting all the 16 municipalities from the P100 million income requirement in RA 9009.

On 22 December 2006, the House of Representatives approved the cityhood bills. The Senate also
approved the cityhood bills in February 2007, except that of Naga, Cebu which was passed on 7 June 2007.
The cityhood bills lapsed into law (Cityhood Laws) on various dates from March to July 2007 without the
President’s signature.

The Cityhood Laws direct the COMELEC to hold plebiscites to determine whether the voters in each
respondent municipality approve of the conversion of their municipality into a city.

Petitioners filed the present petitions to declare the Cityhood Laws unconstitutional for violation of
Section 10, Article X of the Constitution, as well as for violation of the equal protection clause. Petitioners
also lament that the wholesale conversion of municipalities into cities will reduce the share of existing
cities in the Internal Revenue Allotment because more cities will share the same amount of internal
revenue set aside for all cities under Section 285 of the Local Government Code.

Issue:
The petitions raise the following fundamental issues:
1. Whether the Cityhood Laws violate Section 10, Article X of the Constitution; and
2. Whether the Cityhood Laws violate the equal protection clause.

Held:
We grant the petitions.
The Cityhood Laws violate Sections 6 and 10, Article X of the Constitution, and are thus unconstitutional.

First, applying the P100 million income requirement in RA 9009 to the present case is a prospective, not
a retroactive application, because RA 9009 took effect in 2001 while the cityhood bills became law more
than five years later.

Second, the Constitution requires that Congress shall prescribe all the criteria for the creation of a city in
the Local Government Code and not in any other law, including the Cityhood Laws.

Third, the Cityhood Laws violate Section 6, Article X of the Constitution because they prevent a fair and
just distribution of the national taxes to local government units.

Fourth, the criteria prescribed in Section 450 of the Local Government Code, as amended by RA 9009, for
converting a municipality into a city are clear, plain and unambiguous, needing no resort to any statutory
construction.

Fifth, the intent of members of the 11th Congress to exempt certain municipalities from the coverage of
RA 9009 remained an intent and was never written into Section 450 of the Local Government Code.

Sixth, the deliberations of the 11th or 12th Congress on unapproved bills or resolutions are not extrinsic
aids in interpreting a law passed in the 13th Congress.

Seventh, even if the exemption in the Cityhood Laws were written in Section 450 of the Local Government
Code, the exemption would still be unconstitutional for violation of the equal protection clause.

Aquino III V. Comelec

Apr. 7, 2010

Facts:

This is a Petition for Certiorari and Prohibition under Rule 65 of the Rules of Court. Petitioners Senator
Benigno Simeon C. Aquino III and Mayor Jesse Robredo seek the nullification as unconstitutional of
Republic Act No. 9716, entitled “An Act Reapportioning the Composition of the First (1st) and Second
(2nd) Legislative Districts in the Province of Camarines Sur and Thereby Creating a New Legislative District
From Such Reapportionment.”

Republic Act No. 9716 originated from House Bill No. 4264, and was signed into law by President Gloria
Macapagal Arroyo on 12 October 2009. It took effect on 31 October 2009 creating an additional legislative
district for the Province of Camarines Sur by reconfiguring the existing first and second legislative districts
of the province.

The Province of Camarines Sur was estimated to have a population of 1,693,821,2 distributed among four
(4) legislative districts. Following the enactment of Republic Act No. 9716, the first and second districts of
Camarines Sur were reconfigured in order to create an additional legislative district for the province.
Hence, the first district municipalities of Libmanan, Minalabac, Pamplona, Pasacao, and San Fernando
were combined with the second district municipalities of Milaor and Gainza to form a new second
legislative district.

Petitioners contend that the reapportionment introduced by Republic Act No. 9716, runs afoul of the
explicit constitutional standard that requires a minimum population of two hundred fifty thousand
(250,000) for the creation of a legislative district. Petitioners rely on Section 5(3), Article VI of the 1987
Constitution as basis for the cited 250,000 minimum population standard. The provision reads:
(3) Each legislative district shall comprise, as far as practicable, contiguous, compact, and adjacent
territory. Each city with a population of at least two hundred fifty thousand, or each province, shall have
at least one representative.

The petitioners claim that the reconfiguration by Republic Act No. 9716 of the first and second districts of
Camarines Sur is unconstitutional, because the proposed first district will end up with a population of less
than 250,000 or only 176,383.

Issue:
w/n a population of 250,000 is an indispensable constitutional requirement for the creation of a new
legislative district in a province?

Held:
We deny the petition.

Ruling:
There is no specific provision in the Constitution that fixes a 250,000 minimum population that must
compose a legislative district.

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.

Apropos for discussion is the provision of the Local Government Code on the creation of a province which,
by virtue of and upon creation, is entitled to at least a legislative district. Thus, Section 461 of the Local
Government Code states:

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 Twenty million pesos (P20,000,000.00) based on 1991 constant prices and either
of the following requisites:

(i) a contiguous territory of at least two thousand (2,000) square kilometers, as certified by the Lands
Management Bureau; or
(ii) a population of not less than two hundred fifty thousand (250,000) inhabitants as certified by the
National Statistics Office.

Notably, the requirement of population is not an indispensable requirement, but is merely an alternative
addition to the indispensable income requirement.

Aldaba vs COMELEC

Facts:

This case is an original action for Prohibition to declare unconstitutional, 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 merit representative in Congress.

Issue: Whether or not R.A. 9591, “Án act creating a legislative district for the City of Malolos, Bulacan”
is unconstitutional as petitioned. And whether the City of Malolos has at least 250,000 actual or
projected.

Held: It was declared by the Supreme Court that the R.A. 9591 is unconstitutional for being violative of
Section 5 (3), Article VI of the 1987 Constitution and Section 3 of the Ordinance appended to the 1987
Constitution on the grounds that, as required by the 1987 Constitution, a city must have at least 250,000
population. In relation with this, Regional Director Miranda issued a Certification which is based on the
demographic projections, was declared without legal effect because the Regional Director has no basis
and no authority to issue the Certification based on the following statements supported by Section 6 of
E.O. 135 as signed by President Fidel V. Ramos, which provides:
The certification on demographic projection can be issued only if such are declared official by the Nat’l
Statistics Coordination Board. In this case, it was not stated whether the document have been
declared official by the NSCB.

The certification can be issued only by the NSO Administrator or his designated certifying officer, in which
case, the Regional Director of Central Luzon NSO is unauthorized.

The population projection must be as of the middle of the year, which in this case, the Certification issued
by Director Miranda was undated.

It was also computed that the correct figures using the growth rate, even if compounded, the Malolos
population of 223,069 as of August 1, 2007 will grow to only 249,333 as of August 1, 2010.

It was emphasized that the 1935 Constitution, that this Court ruled that the aim of legislative
reappointment is to equalize the population and voting power among districts.

Griño vs. COMELEC

G.R. No. 105120 September 2, 1992

FACTS:

Griño and his LDP political party filed a certiorari case against COMELEC in relation to the May 11, 1992
election. Griño is a candidate for Governor of Iloilo where the sub-province of Guimaras is located. LGC of
1991 took effect requiring the conversion of existing sub-provinces into regular provinces, and Guimaras
is one such sub-provinces, upon approval by majority of votes cast in a plebiscite. The plebiscite favored
the conversion of Guimaras into a regular province but petitioner questioned the COMELEC that ballots
should have contained spaces to allow voting for Gov, Vice Gov and members of the Sanggunian of Iloilo.

ISSUE:

Whether or not there was a complete failure of election in Guimaras.

HELD:

The court held that COMELEC was under mistaken presumption that under the LGC of 1991, whether or
not the conversion of Guimaras into a regular province is ratified by the people in plebiscite, the President
will appoint provincial officials. However, the voters favored for the conversion of Guimaras into a regular
province so there was need to undo what COMELEC has done in plebiscite. There ballots in Guimaras
should have contained spaces for Gov and Vice Gov. etc. but SC has now considered the case moot and
academic since majority voted in the affirmative for the conversion of Guimaras.
Samson vs Aguirre

SUMMARY: Samson, a councilor in Quezon City, assailed RA 8535 which created the City of Novaliches.
According to him, the RA failed to conform to the requirements of the LGC as to certifications in income,
population, and land area. It has not been proved that the mother city would not suffer adverse effects
from the creation of Novaliches. Court held against him. The presence and oral declarations of the
government officials armed with records during the public deliberations and hearings are more effective
certifications than mere certificates which are routinely signed. The representatives all declared that
Novaliches exceeded the requirements. The QC mayor was also present, and his conformity implies that
there is no damage done to QC. The non-receipt of copies is too insubstantial to sustain invalidity of a
statute. Samson failed to overturn the presumption of constitutionality accorded legislative acts.

FACTS:

President Ramos signed into law RA 8535, creating the City of Novaliches out of 15 barangays of Quezon
City. Samson, incumbent councilor of the first district of Quezon City, challenged the constitutionality of
the RA. He sought to enjoin its implementation, holding of the plebiscite, and disbursement of funds as
RA 8535 failed to conform to the criteria in the LGC as to income, population, land area, seat of
government, having no adverse effect to its mother city, and furnishing a copy of the barangay resolution.
Also, he said the law would amend the Constitution.

In answer, the respondents claimed Samson failed to substantiate said allegations with convincing
proof. He had the burden of proof to overcome the legal presumption that Congress considered all the
legal requirements under the Local Government Code of 1991 in passing R.A. 8535. Further, there is no
document supporting the unconstitutionality claim.

ISSUE: Was RA 8535 unconstitutional? NO.

 There is a presumption of constitutionality in favor of a statute. One who attacks a statute must prove
its invalidity beyond a reasonable doubt. Samson has failed to discharge the burden.

1. Samson did not present any proof, only allegations, that no certifications were submitted to
the House Committee on Local Government—as such certifications attesting compliance with the
LGC and its IRR is required. Allegations cannot substitute for proof. The presumption stands that
the law passed by Congress complied with all the requisites.

a. The representative from the Bureau of Local Government Finance estimated the
combined average annual income of the 13 barangays for 2 years to be around P27M.
Under the Local Government Code, a proposed city must have an average annual income
of only at least P20,000,000.00 for the immediately preceding two years.

b. The representative from the NSO estimated the population in the barangays that would
comprise the proposed City of Novaliches to be around 350,000. This figure is more than
the 150,000 required by the Implementing Rules.

c. There is no need to consider the land area, given these figures, since under the Local
Government Code, the proposed city must comply with requirements as regards income
and population or land area. Other than the income requirement, the proposed city must
have the requisite number of inhabitants or land area. Compliance with either
 requirement, in addition to income, is sufficient. Judicial notice may also be taken that
Novaliches is now highly urbanized.

2. Samson averred that oral manifestations are not enough certification. But in the hearings, the
DBM, DILG, and Finance Officials were present along with other officers armed with official
statistics and reference materials. In their official capacity, they spoke and shed light on
population, land area and income of the proposed city. Their official statements could serve the
same purpose contemplated by law requiring certificates. Their affirmation as well as their oath
as witnesses in open session of either the Senate or the House of Representatives give even
greater solemnity than a certification submitted to either chamber routinely.

3. Samson failed to show that the representatives did not also submit written certifications. Under
the IRR, written certifications are required to be attached to the petition for the creation of a city,
to be submitted by interested municipalities or barangays to Congress in the form of a
resolution. Samson did not present a copy to prove that it was without the written certifications
attached as required by law. It is presumed that these requirements were met appropriately in
the passage of the assailed legislative act.

 Samson argued that the RA failed to specify the seat of government of the proposed City of Novaliches
as required. However, this omission is not as fatal to the validity. Under Section 12 of the Local
Government Code, the City of Novaliches can still establish a seat of government after its creation.
While Section 12 speaks of the site of government centers, such site can very well also be the seat of
government, “from where governmental and corporate service shall be delivered.”

 Samson failed to present any concrete evidence on the adverse effect to Quezon City. Quezon City
Mayor Mathay was present during the deliberations and made no mention of anything concerning
such. As chief executive, he would be the first person to protest any development that might prove
detrimental to Quezon City. This is indicative of the non-existence of such negative issues. Moreover,
in the plebiscite, all persons concerned will obviously have the opportunity to raise those issues even
before they vote on the principal question of the cityhood of Novaliches.

 That the Quezon City Council was not furnished a copy of the petition of concerned barangays calling
for the creation of the City of Novaliches, if true, will also not render invalid the RA. The evident
purpose of this requirement, found in the Implementing Rules, is to inform the City Council of the
move to create another city and to enable it to formulate its comments and recommendations on said
petition. The Quezon City Council members are obviously aware of the petition. The matter has been
widely publicized in the mass media. Surely members of the Council could not now be heard to claim
they have not known of the contents of the barangays’ petition to create the City of Novaliches.

The proposed creation of the City of Novaliches will in no way result in a prohibited amendment of the
Constitution. The ordinance appended to the Constitution merely apportions the seats of the House of
Representatives to the different legislative districts in the country. Nowhere does it provide that Metro
Manila shall forever be composed of only 17 cities and municipalities as claimed by petitioner. Too literal
a reading of the ordinance in or appendix of the Constitution will only result in its erroneous
interpretation.
Lidasan vs COMELEC

FACTS:

Bara Lidasan was a resident of Parang, Cotabato. Later, Republic Act No. 4790, entitled “An Act Creating
the Municipality of Dianaton in the Province of Lanao del Sur,” was passed. Lidasan however discovered
that certain barrios located in Cotabato were included in Dianaton, Lanao Del Sur pursuant to RA
4790. [Remarkably, even the Congressman of Cotabato voted in favor of RA 4790.] Pursuant to this law,
COMELEC proceeded to establish precincts for voter registration in the said territories of Dianaton.
Lidasan then filed a case to have RA 4790 be nullified for being unconstitutional. He averred that the
law did not clearly indicate in its title that in creating Dianaton, it would be including in its territory
several barrios from Cotabato.

ISSUE: Is RA 4790, which created Dianaton but which includes barrios located in another province –
Cotabato – to be spared from attack planted upon the constitutional mandate that “No bill which may be
enacted into law shall embrace more than one subject which shall be expressed in the title of the bill”?

HELD: No. The said law is void. The baneful effect of the defective title here presented is not so difficult
to perceive. Such title did not inform the members of Congress as to the full impact of the law; it did not
apprise the people in the towns of Buldon and Parang in Cotabato and in the province of Cotabato itself
that part of their territory is being taken away from their towns and province and added to the adjacent
Province of Lanao del Sur; it kept the public in the dark as to what towns and provinces were actually
affected by the bill that even a Congressman from Cotabato voted for it only to find out later on that it is
to the prejudice of his own province. These are the pressures which heavily weigh against the
constitutionality of RA 4790.