LEAGUE OF CITIES VS.

COMELEC
FACTS:
During the 11th Congress, 33 bills converting 33 municipalities into cities. However, Congress did
not act on bills converting 24 other municipalities into cities.
During the 12th Congress, enacted RA 9009 into a law which increased the annual income
requirement for city from 20 million to 100 million. After the effectivity of RA9009, the House of
Representatives of the 12th Congress adopted Resolution No. 29 which sought to exempt from the 100
million requirement for the 24 municipalities whose cityhood bills were not approved during the 11th
Congress.The 12th Congress ended without the Senate approving the said resolution.
The 13th Congress 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. However,
there were 16 municipalities through their respective sponsors were exempted from the 100 million
income requirement in RA 9009.
The House of Representatives approved the cityhood bills except Naga, Cebu. The cityhood bills
lapsed into law without the President’s signature.
The Cityhood Laws direct the COMELEC to hold plebiscites to determine whether the votes in
each respondent municipality approve of the conversion of their municipality into a city.

ISSUE: Whether or not the Cityhood Laws violate Sec. 10, Article 10 of the Constitution

RULING:
“In enacting RA 9009, Congress did not grant any exemption to respondent municipalities, even
though their cityhood bills were pending in Congress when Congress passed RA 9009. The Cityhood
Laws, all enacted after the effectivity of RA 9009, explicitly exempt respondent municipalities from the
increased income requirement in Section 450 of the Local Government Code, as amended by RA
9009. Such exemption clearly violates Section 10, Article X of the Constitution and is thus patently
unconstitutional. To be valid, such exemption must be written in the Local Government Code and not
in any other law, including the Cityhood Laws.”
“Uniform and non-discriminatory criteria as prescribed in the Local Government Code are
essential to implement a fair and equitable distribution of national taxes to all local government units.
Section 6, Article X of the Constitution provides:
Local government units shall have a just share, as determined by law, in the national taxes which shall
be automatically released to them. (Emphasis supplied)
If the criteria in creating local government units are not uniform and discriminatory, there can
be no fair and just distribution of the national taxes to local government units.
A city with an annual income of only P20 million, all other criteria being equal, should not
receive the same share in national taxes as a city with an annual income of P100 million or more. The
criteria of land area, population and income, as prescribed in Section 450 of the Local Government
Code, must be strictly followed because such criteria, prescribed by law, are material in determining the
"just share" of local government units in national taxes. Since the Cityhood Laws do not follow the
income criterion in Section 450 of the Local Government Code, they prevent the fair and just
distribution of the Internal Revenue Allotment in violation of Section 6, Article X of the Constitution.”
LLAMANZARES VS. COMELEC
FACTS:
Grace Poe was found abandoned in a church in Jaro Iloilo. The child was then found and
adopted by Fernando Poe, Jr and Susan Roces.
Necessary annotations were placed in the child’s foundling certificate but it was only in 2005
that Susan Roces discovered that their lawyer failed to secure a new Certificate of Live Birth indicating
Poe’s new name as well as the name of the adoptive parents. Roces then submitted an affidavit then a
Certifcate of Live Birth with Grace Poe’s new name was released.
Grace Poe then registered as a voter with the local COMELEC and was issued a Philippine
passport. She was eventually married to Teodoro Llamanzares and flew to the US right after the
wedding and became a naturalized American Citizen and obtained a US Passport.
She and her children were then considered dual citizens after Poe took her Oath of Allegiance to
the Republic of the Philippines pursuant to RA9225 in behalf of her three children. She registered as a
voter and secured a Philippine passport thereafter.
Poe filed with COMELEC her Certificate of Candidacy for Senator stating that she was a resident
of the Philippines and was then proclaimed Senatior on May, 2005.
During the May 2016 elections, she filed her COC and declared that she is a natural born and her
residence in the Philippines would be 10 years and 11 months from May 24, 2005.
ISSUE: Whether or not Grace Poe is a natural born citizen?
RULING:
 “Current legislation reveals the adherence of the Philippines to this generally accepted principle
of international law. In particular, R.A. No. 8552, R.A. No. 8042 and this Court's Rules on Adoption,
expressly refer to "Filipino children." In all of them, foundlings are among the Filipino children who could
be adopted. Likewise, it has been pointed that the DFA issues passports to foundlings. Passports are by
law, issued only to citizens. This shows that even the executive department, acting through the DFA,
considers foundlings as Philippine citizens.”
“Adopting these legal principles from the 1930 Hague Convention and the 1961 Convention on
Statelessness is rational and reasonable and consistent with the jus sanguinis regime in our Constitution.
The presumption of natural-born citizenship of foundlings stems from the presumption that their
parents are nationals of the Philippines. As the empirical data provided by the PSA show, that
presumption is at more than 99% and is a virtual certainty.”
“In sum, all of the international law conventions and instruments on the matter of nationality of
foundlings were designed to address the plight of a defenseless class which suffers from a misfortune
not of their own making. We cannot be restrictive as to their application if we are a country which calls
itself civilized and a member of the community of nations. The Solicitor General's warning in his opening
statement is relevant:”
Lastly, it was repeatedly pointed out during the oral arguments that petitioner committed a
falsehood when she put in the spaces for "born to" in her application for repatriation under R.A. No.
9225 the names of her adoptive parents, and this misled the BI to presume that she was a natural-born
Filipino. It has been contended that the data required were the names of her biological parents which
are precisely unknown.
LAGMAN VS. MEDIALDEA
FACTS:
Due to Marawi Siege and continues attacks by the Maute terrorist group, President Rodrigo
Duterte issued Proclamation No. 216 declaring a state of martial law and suspending the privilege of the
writ of habeas corpus in the whole Mindanao on the grounds of invasion or rebellion as stated in the
Constitution.
Petitioner Lagman claims that the declaration of martial law has no sufficient factual basis
because there is no rebellion or invasion in Marawi City or in any part of Mindanao. They content that
that the acts of terrorism in Mindanao do not constitute rebellion since there is not proof that its
purpose is to remove Mindanao or any part thereof from allegiance to the Philippines, its laws or its
territory. Hence the case.
ISSUE: Whether or not the declaration of martial law has sufficient factual basis under Section 18,
Article VII of the Constitution?
RULING:
We conclude, therefore, that Section 18, Article VII limits the scope of judicial review by the
introduction of the "sufficiency of the factual basis" test.
As Commander-in-Chief, the President has the sole discretion to declare martial law and/or to suspend
the privilege of the writ of habeas corpus, subject to the revocation of Congress and the review of this
Court. Since the exercise of these powers is a judgment call of the President, the determination of this
Court as to whether there is sufficient factual basis for the exercise of such, must be based only on facts
or information known by or available to the President at the time he made the declaration or
suspension, which facts or information are found in the proclamation as well as the written Report
submitted by him to Congress. These may be based on the situation existing at the time the declaration
was made or past events. As to how far the past events should be from the present depends on the
President.
“Hence, the maxim falsus in uno, falsus in omnibus finds no application in this case. Falsities of
and/or inaccuracies in some of the facts stated in the proclamation and the written report are not
enough reasons for the Court to invalidate the declaration and/or suspension as long as there are other
facts in the proclamation and the written Report that support the conclusion that there is an actual
invasion or rebellion and that public safety requires the declaration and/or suspension.”
“In sum, the Court's power to review is limited to the determination of whether the President in
declaring martial law and suspending the privilege of the writ of habeas corpus had sufficient factual
basis. Thus, our review would be limited to an examination on whether the President acted within the
bounds set by the Constitution, i.e., whether the facts in his possession prior to and at the time of the
declaration or suspension are sufficient for him to declare martial law or suspend the privilege of the
writ of habeas corpus.”