Romulo B. Macalintal v. Office of the President, et al. — Decision — Official PDF

Decision il G.R. No. E-08557 Pilipinas and of punong barangays elected in the October 2023 BSKE, who likewise invoked the effect of the case on the length of their stay in office.2* Larida stands in no different position. Neither would Larida’s participation aid the Court in resolving the case. His Comment-in-Intervention raises no argument that respondents, through the OSG, have not already presented: that the Petition questions the wisdom, rather than the validity, of the law; and that Republic Act No. 12326, like Republic Act No. 12232, is a term-fixing law to which the 2023 Macalintal guidelines do not apply. 25 His intervention would add a party to the case, but not an issue. Larida’s argument that a five-year term would enable barangay officials to develop proficiency in preparing the Annual Barangay Budget and the Barangay Development Plan”® raises policy considerations. They are properly addressed to Congress, which, as discussed below, weighed similar considerations in enacting Republic Act No. 12326. They do not bear on the question of constitutionality before the Court. i. The determination of the term of barangay officials is a_ political question only insofar as its wisdom is concerned Respondents argue that determining the term of barangay officials is a political question. They are correct insofar as the wisdom of that determination is concerned. As the Court explained in COMELEC v. Cruz,” “whatever Congress, in its wisdom, decides on these matters are political questions beyond the pale of judicial scrutiny, subject only to the certiorari jurisdiction of the courts provided under Section 1, Article VII of the Constitution and to the judicial authority to invalidate any law contrary to the Constitution.” The Petition, however, does not merely question the wisdom of a five-year term. It alleges that Republic Act No. 12326 transgresses specific constitutional limitations: the right of suffrage, substantive due process, the requirement that barangay officials be elected, and the one subject-one title rule. Whether Congress kept within these limits is a question the Court is bound to answer under its expanded power of judicial review. What the Court may not do, in answering it, is substitute its own judgment for that of Congress on how long barangay officials should serve, or on whether the reasons for the law are wise. : 24 id. > Comment-in-Intervention, pp. 1-5, % Id at 6-11. 27 620 Phil. 175, 196 (2009) [Per J. Brion, Ex Bunc}. (Citations omitted)