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

Decision 12 G.R. No. E-08557 With these parameters in mind, the Court turns to the substantive issues. IV. Republic Act No. 12326 is a term- fixing law to which the 2023 Macalintal guidelines do not apply The determination of a law’s fundamental character begins with its text. In 2025 Macalintal, the Court distinguished Republic Act No. 12232 from the election-postponement laws that preceded it, including Republic Act No. 11935, which was struck down in 2023 Macalintal. We noted that Republic Act No. 12232 is titled as an act “setting” the term of office of barangay officials, not one “postponing” an election; that it does not amend Republic Act No. 9164, as the postponement laws did; that it prescribes a new term for BSK officials, whereas the postponement laws retained the three-year term; and that it sets a new interval between elections. On these bases, the Court held that Republic Act No. 12232 is fundamentally a term- setting law, and that “since Republic Act No. 12232 is not primarily an election postponement jaw, the Macalintal 2023 guidelines become inapplicable. Each of these markers appears in Republic Act No. 12326. Its title describes it as an act “Fixing the Term of Office of Barangay Officials and Members of the Sangguniang Kabataan to Five [] Years.” It amends Republic Act No. 12232, a term-setting law, and not Republic Act No. 9164. it changes the term structure: it lengthens the term from four to five years and reduces the consecutive-term limit for barangay officials from three terms to two. It sets a new five-year interval between elections. its principal purpose, as gleaned from its text, is to fix the term of barangay and SK officials. Setting the next BSKE for November 2028 implements the new term, and is not an independent objective. The rest of the provisions of Republic Act No. 12326 confirm this. Section 4-B, inserted by Section 4 of Republic Act No. 12326, directs the institutionalization of training and capacity-building programs for barangay and SK officials “[c]onsistent with the [five-year] term of office established under this Act.”?8 Macalintal seeks to show otherwise by pointing to news reports that headlined the law as one that “postpones” the BSKE, and to the explanation given at a media briefing when the signing of the law was announced.’ These do not alter the character of the law. What a law is depends on what it says and what it principaily seeks to accomplish, not on how it is described in the press. 28 Republic Act No. 12326, sec. 4. 2) Petition, pp. 2-3, 19-20.