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Manuel T. de Guia VS. Comelec: G.R. No. 104712 May 6,1992 Bellosollo, J.

This document summarizes a Supreme Court case regarding the election of local government officials in Metro Manila under Republic Act 7166. The Court ruled that (1) Sangguniang Bayan members in Parañaque and other Metro Manila municipalities would be elected by district in the May 1992 elections, as these areas had been apportioned into two districts, and (2) Sangguniang Panlungsod members of single-district cities and Sangguniang Bayan members of municipalities outside Metro Manila would continue to be elected at-large in May 1992, but would transition to district-based elections starting in 1995 to fully implement the spirit of RA 7166.

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294 views10 pages

Manuel T. de Guia VS. Comelec: G.R. No. 104712 May 6,1992 Bellosollo, J.

This document summarizes a Supreme Court case regarding the election of local government officials in Metro Manila under Republic Act 7166. The Court ruled that (1) Sangguniang Bayan members in Parañaque and other Metro Manila municipalities would be elected by district in the May 1992 elections, as these areas had been apportioned into two districts, and (2) Sangguniang Panlungsod members of single-district cities and Sangguniang Bayan members of municipalities outside Metro Manila would continue to be elected at-large in May 1992, but would transition to district-based elections starting in 1995 to fully implement the spirit of RA 7166.

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MJ
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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MANUEL T.

DE GUIA
VS.
COMELEC

G.R. No. 104712


May 6,1992
Bellosollo, J.:
FAC

TS
On November 18, 1991, Congress passed RA
7166
“An Act providing for Synchronized National and Local Elections and for Electoral Reforms,
Authorizing Appropriations therefore, and for other purposes. “

 On November 20, 1991, COMELEC issued Resolution


No. 2313 and the subsequent resolutions in question.

 Petitioner De Guia, filed with COMELEC a motion for


clarification of its Resolution No. 2313 on February 20,
1992.
FAC
TS
 COMELEC issued Resolution No. 2379 stating that
its purpose in recommending to Congress the
apportionment of Sangguniang Panglungsod and
Bayan seats to reduce the number of candidates
to be voted for.

 Petitioner De Guia received the copy of the


Resolution but still filed an instant petition for
reversal of the position of the respondent.
ISSU

E
Whether the Members of the Sangguniang Bayan
of Parañaque and other municipalities of
Metro Manila enumerated therein, would be
elected by district in the May 11, 1992
regular elections?
RULI
NG
 Yes. As stated in Par. (c) Sec. 3, Cities
with 2 or more legislative districts
(Manila, Cebu, Davao) shall continue to be
elected by district, as well as the 13 Mun.
of Metro Manila which have already been
apportioned into 2 districts.
RULI
NG
 Par. (d) Sec. 3 of RA 7166 refers only to elective
officials of the Sangguniang Panglungsod which
are single district cities and Sangguniang
Bayan for Municipalities outside Metro Manila,
which will remain to be elected at large in the
May 11, 1992 election.
Spirit and purpose of the
law

 The reason for the promulgation of


R.A. 7166 is shown in the explanatory
note of Senate Bill No. 1861, and
that respondent COMELEC is cognizant
of its legislative intent.
Spirit and purpose of the
law
 No law is ever enacted that is intended to be
meaningless, much less inutile. We must
therefore, as far as we can, divine its
meaning, its significance, its reason for
being. As it has oft been held, the key to
open the door to what the legislature
intended which is vaguely expressed in the
language of a statute is its purpose or the
reason which induced it to enact the statute.
Spirit and purpose of the
law
 The true import of Par. (d) is that
Sangguniang Panlungsod of the single-district
cities and the Sangguniang Bayan of the
municipalities outside Metro Manila, which
remained single-districts not having been
ordered apportioned under Sec. 3 of R.A. 7166
will have to continue to be elected at large
in the May 11, 1992, elections, although
starting 1995 they shall all be elected by
district to effect the full implementation of
the letter and spirit of R.A. 7166.
Thank you!

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