League of Cities v. COMELEC: The Finality of the 16 Cityhood Laws

The Supreme Court’s June 28, 2011 Resolution in League of Cities of the Philippines v. Commission on Elections (G.R. Nos. 176951, 177499, and 178056) put an end to a long-running legal battle over the constitutionality of sixteen laws converting municipalities into cities. By denying the petitioners’ second motion for reconsideration and granting entry of judgment, the Court affirmed with finality that the Cityhood Laws—Republic Acts Nos. 9389, 9390, 9391, 9392, 9393, 9394, 9398, 9404, 9405, 9407, 9408, 9409, 9434, 9435, 9436, and 9491—are constitutional. The ruling is significant not only for the affected local governments but also for clarifying the strict procedural rules on finality of judgments.

Background of the Case

The petitioners, the League of Cities of the Philippines and others, challenged the constitutionality of sixteen laws that converted respondent municipalities into cities. The core dispute centered on whether these laws complied with the criteria for creating cities under the Local Government Code (Republic Act No. 7160), particularly the income requirement.

The controversy arose after Republic Act No. 9009 amended the Local Government Code, increasing the annual income requirement for cityhood from P20 million to P100 million. The sixteen Cityhood Laws, however, exempted the respondent municipalities from this new requirement, allowing them to qualify based on the old P20 million threshold because their conversion bills were pending during the 11th Congress.

The Issue

The central issue was whether the sixteen Cityhood Laws violated the Constitution. Specifically, the petitioners argued that the laws contravened Article X, Sections 6 and 10 of the 1987 Constitution, which require that the creation of local government units follow the criteria established in the Local Government Code and that local governments receive a just share in national taxes. The petitioners also claimed the laws violated the equal protection clause.

The Court’s Ruling

The Supreme Court, in its Resolution dated February 15, 2011, granted the respondents’ motion for reconsideration and declared the Cityhood Laws constitutional. The Court reasoned that the conversion bills were pending during the 11th Congress and that the municipalities had complied with the requirements of the Local Government Code prior to its amendment by Republic Act No. 9009.

In the June 28, 2011 Resolution, the Court denied the petitioners’ subsequent motion for reconsideration. The Court noted that this motion was actually a second motion for reconsideration, which is a prohibited pleading under Section 2, Rule 51 of the Rules of Court. The Court emphasized that a second motion for reconsideration may only be entertained in the higher interest of justice, upon a vote of at least two-thirds of the Court’s actual membership, and only before the ruling becomes final.

The Court observed that the petitioners’ motion merely rehashed issues already raised in their earlier Ad Cautelam Motion for Reconsideration. Since the Court had already passed upon these issues with finality, there was no need to discuss them again. The Court also noted that the ruling sought to be reconsidered had already become final by the Court’s express declaration, making the denial of the motion immediately warranted.

The Dissenting Opinions

Justices Carpio and Sereno maintained their dissents. Justice Carpio argued that the Cityhood Laws violated Article X, Section 10 of the Constitution because the criteria for creating cities must be established in the Local Government Code itself, not in separate laws. He also contended that the laws violated the equal protection clause by granting an exemption based on the arbitrary fact of having pending bills during the 11th Congress.

Justice Sereno expressed concern about the Court’s “flip-flopping” decisions, noting that the constitutionality of the Cityhood Laws had been reviewed no less than five times. She argued that the Court’s indecision undermined public confidence in the stability of judicial precedents and the rule of law.

Practical Takeaways

• Second motions for reconsideration are generally prohibited. Under Section 2, Rule 51 of the Rules of Court, a second motion for reconsideration of a judgment or final resolution by the same party will not be entertained, except in the higher interest of justice with a two-thirds vote of the Court en banc.
• Finality of judgments is crucial. Once a ruling becomes final, it is immutable and can no longer be modified, even if errors are later discovered, except in narrowly defined circumstances such as clerical errors, void judgments, or supervening events.
• The income requirement for cityhood is now settled. The sixteen Cityhood Laws are constitutional, and the respondent municipalities may validly convert into cities based on the criteria existing before the amendment by Republic Act No. 9009.
• For future conversions, the P100 million income requirement applies. Municipalities seeking cityhood after the effectivity of Republic Act No. 9009 must comply with the amended income requirement under the Local Government Code.
• Legislative remedies, not judicial ones, are the proper avenue for changing cityhood criteria. If Congress wishes to adjust the standards for creating cities, it must directly amend the Local Government Code rather than enacting piecemeal exemptions.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.