You are on page 1of 3

G.R. No.

96754 June 22, 1995

CONGRESSMAN JAMES L. CHIONGBIAN (Third District, South Cotobato) ADELBERT W.


ANTONINO (First District, South Cotobato), WILFREDO G. CAINGLET (Third District,
Zamboanga del Norte), HILARION RAMIRO, JR. (Second Division, Misamis Occidental),
ERNESTO S. AMATONG (Second District, Zamboanga del Norte), ALVIN G. DANS (Lone
District, Basilan), ABDULLAH M. DIMAPORO (Second District, Lanao del Norte), and
CONGRESSWOMAN MARIA CLARA A. LOBREGAT (Lone District, Zamboanga City)
petitioners,
vs.
HON. OSCAR M. ORBOS, Executive Secretary; COMMITTEE CHAIRMAN SEC. FIDEL V.
RAMOS, CABINET OFFICERS FOR REGIONAL DEVELOPMENT FOR REGIONS X AND XII,
CHAIRMAN OF THE REGIONAL DEVELOPMENT COUNCIL FOR REGION X, CHAIRMAN
JESUS V. AYALA, CABINET OFFICERS FOR REGIONAL DEVELOPMENT FOR REGIONS XI
and XII, DEPARTMENT OF LOCAL GOVERNMENT, NATIONAL ECONOMIC AND
DEVELOPMENT AUTHORITY SECRETARIAT, PRESIDENTIAL MANAGEMENT STAFF, HON.
GUILLERMO CARAGUE, Secretary of the DEPARTMENT OF BUDGET and MANAGEMENT;
and HON. ROSALINA S. CAJUCUM, OIC National Treasurer, respondents.

IMMANUEL JALDON, petitioner,


vs.
HON. EXECUTIVE SECRETARY OSCAR M. ORBOS, HON. FIDEL RAMOS, HON. SECRETARY
LUIS SANTOS, AND HON. NATIONAL TREASURER ROSALINA CAJUCOM, respondents.

FACTS:

In compliance with Section 18 of Article X of the 1987 Constitution, Republic Act


6724, known as the organic act for the Autonomous Region in Muslim Mindanao
(ARMM), was enacted by Congress. This law mandated a plebiscite in 23 provinces to
determine which areas would agree to become part of the autonomous region.

Lanao Del Sur, Maguindanao, Sulu, and Tawi-Tawi were the provinces that voted
affirmatively for the establishment of the autonomous region, forming the ARMM as
specified in R.A. 6734.

Regarding the provinces that did not choose to join ARMM, R.A. 6724 stated that
they would remain in their current administrative regions. Nevertheless, it also granted
the President the authority, through administrative determination, to merge these
existing regions.
Acting on this authority, then-President Aquino issued Executive Order No. 429,
titled "PROVIDING FOR THE REORGANIZATION OF THE ARMM." This EO entailed
relocating provinces that did not opt to join ARMM to a different region.

Congressman James Chiongban and other petitioners contested the validity of


E.O. 429. They argued that there is no existing law that empowers the president to
modify the structure of governmental units, i.e., no provision calls for presidential
"reorganization" under current legislation.

They also contended that the authority to "merge" granted in R.A. 6724 does not
inherently encompass the power to "reorganize," even if it does not impact the
allocation of congressional representatives.

Lastly, they asserted that Article XIX Section 13 of R.A. 6724 is unconstitutional,
as it constitutes an improper delegation of power from the legislature to the President,
and the granted authority is not expressly mentioned in the law's title.

ISSUE:
Whether Sec. 13 of Article XIX of R.A. 724 is invalid.

HELD:

No.The Supreme Court clarified that a legislative standard doesn't necessarily


have to be explicitly stated and can be inferred by examining the entire law along with
other relevant statutes. This standard may not exclusively reside in the law being
challenged; it may also be encapsulated in other laws dealing with the same subject
matter.

Regarding the authority to merge existing administrative regions, the standard is


rooted in the same policy that underlies the grant of power to the President in R.A.
5435, allowing for the reorganization of the Executive department. This aims to
streamline government operations, enhance efficiency, and control costs, enabling it to
pursue programs aligned with national development goals and improve public service.

Selecting the President as the delegate for this administrative function is logical,
as the regional division of the country serves not only to manage local governments but
also to coordinate executive departments, as mandated by law to have regional offices.

While the Constitution doesn't explicitly outline the power to merge administrative
regions, it is a authority traditionally vested in the President to facilitate the exercise of
general supervision over local governments.

It's crucial to note that these regions don't constitute territorial and political
divisions like provinces, cities, municipalities, and barangays. Instead, they are
groupings of adjacent provinces established for administrative convenience. The
authority granted to the President is akin to the power to adjust municipal boundaries,
classified as an administrative function.

You might also like