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

Decision 14 G.R. No. E-08557 Neither may the term of office under Section 1 of Republic Act No. 12326 be treated as separate and distinct from the date of the elections under Section 2, because one is not necessarily implied by the other. That is the very proposition that 2025 Macalintal rejected. There, the Court held that the express grant to Congress of the power to determine the term of barangay officials “necessarily carries with it, the power to determine when that determined term begins and when it ends,” and that these “temporal components are not severable from the power to set the term itself—they are integral, subsidiary elements that give meaning and effect to the express constitutional grant of authority.”>! Because the power to fix the term includes the power to fix its commencement and the election date, the election date cannot be detached from the term and measured against standards, such as the 2023 Macalintal guidelines, crafted for laws whose purpose is to postpone elections. That the term and the election date appear in separate sections of Republic Act No. 12326 does not make them separate subjects. A five-year term must begin and end on some date, and the election that fills the office must be held on some date. Sections 1 and 2 are two parts of one structure: the five-year term and the five-year election cycle that gives it effect. Neither is the analysis altered by the views of individual legislators that the five-year term could have been applied prospectively, beginning with the officials to be elected in November 2026.*? These views show that the alternative was raised and debated in both chambers. They also show that it was not adopted. That some members of Congress preferred a different transition to the new term does not change the character of the choice that Congress, as a body, made. How to move from one term structure to another is part of the power to determine the term, and the Court may not substitute the option it prefers for the one Congress chose. As earlier discussed, the acknowledgment in the legislative record that Republic Act No. 12326 has the effect of moving the BSKE does not change the primary character of the law. V. The November 2028 Gate is reasonable and not unduly long This is not to say that Congress’s power to fix the term of barangay officials is without limit. In 2G25 Macalintal, the Court heid that the power to fix the term carries with it the power to determine when the new term starts, “provided that such determined period is reasonable and should not be unduly long from the time cf the enactment of the law setting the new 3! Macalintal v. Senate of the Philippines, G.R. Nos. E-92002, E-02010, E-02142 & E-02276, November LL, 2025 [Per J. Lopez, J., En Banc}. 32 Td, at 37-38.