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19 CASE DIGEST - G.R. No. 174153 - Lambino vs. Commission On Elections, Oct 25, 2006

The Supreme Court dismissed the petition by the Lambino Group seeking to amend the Philippine Constitution through a people's initiative, ruling that the proposed changes constituted a revision and did not meet the constitutional requirements for such an initiative. The Court found that the petition failed to provide the full text of the proposed amendments and did not comply with the necessary voter representation criteria. Additionally, the Court upheld the previous ruling in Santiago v. COMELEC, stating that the Commission on Elections did not commit grave abuse of discretion in denying the petition.

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36 views2 pages

19 CASE DIGEST - G.R. No. 174153 - Lambino vs. Commission On Elections, Oct 25, 2006

The Supreme Court dismissed the petition by the Lambino Group seeking to amend the Philippine Constitution through a people's initiative, ruling that the proposed changes constituted a revision and did not meet the constitutional requirements for such an initiative. The Court found that the petition failed to provide the full text of the proposed amendments and did not comply with the necessary voter representation criteria. Additionally, the Court upheld the previous ruling in Santiago v. COMELEC, stating that the Commission on Elections did not commit grave abuse of discretion in denying the petition.

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annwincatamco
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Title

Lambino vs. Commission on Elections


Case
G.R. No. 174153
Decision Date
Oct 25, 2006
The Supreme Court dismisses a petition seeking to amend the Constitution
through a people's initiative, ruling that the proposed changes constitute a
revision and cannot be implemented through this process.

Facts:
 Petitioners Raul L. Lambino and Erico B. Aumentado, along with 6,327,952
registered voters, filed a petition with the Commission on Elections (COMELEC)
on August 25, 2006.
 The petition sought to amend the 1987 Philippine Constitution to shift from a
bicameral-presidential system to a unicameral-parliamentary system.
 Petitioners claimed their initiative had the support of at least 12% of all registered
voters, with each legislative district represented by at least 3% of its registered
voters.
 COMELEC denied due course to the petition on August 31, 2006, citing the
Supreme Court's ruling in Santiago v. COMELEC (1997), which declared there
was no sufficient law to implement the initiative clause for amending the
Constitution.
 Petitioners elevated the case to the Supreme Court, arguing that COMELEC
committed grave abuse of discretion in dismissing their petition.

Issue:
1. Whether the Lambino Group's initiative petition complies with Section 2, Article
XVII of the Constitution on amendments to the Constitution through a people's
initiative.
2. Whether the Supreme Court should revisit its ruling in Santiago v.
COMELEC declaring RA 6735 "incomplete, inadequate or wanting in essential
terms and conditions" to implement the initiative clause on proposals to amend
the Constitution.
3. Whether the COMELEC committed grave abuse of discretion in denying due
course to the Lambino Group's petition.
Ruling:
 The Supreme Court dismissed the petition.
 The Court ruled that the Lambino Group's initiative petition did not comply with
the basic requirements of the Constitution for conducting a people's initiative.
 The Court found no need to revisit the Santiago ruling, as the present petition
warranted dismissal based on the Lambino Group's failure to comply with
constitutional requirements.
 The COMELEC did not commit grave abuse of discretion in following the Court's
ruling in Santiago.

Ratio:
 The Lambino Group's initiative petition did not comply with Section 2, Article
XVII of the Constitution, which requires amendments to be directly proposed by
the people through an initiative upon a petition of at least 12% of the total
number of registered voters, with each legislative district represented by at least
3% of the registered voters therein.
 The full text of the proposed amendments must be shown to the people before
they sign the petition.
 The Lambino Group failed to attach the full text of the proposed amendments to
the signature sheets, and the signature sheets did not indicate that the text was
attached. This omission was deemed fatal to the initiative.
 A people's initiative can only propose amendments, not revisions, to the
Constitution. The proposed changes by the Lambino Group, which included
shifting from a bicameral-presidential to a unicameral-parliamentary system,
constituted a revision rather than an amendment.
 The COMELEC's reliance on the Santiago ruling was appropriate and did not
constitute grave abuse of discretion

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