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

Decision 16 G.R. No. E-08557 Second, Congress explained why the next BSKE could not reasonably be set earlier. According to the legislative record cited by respondents, proceeding with the BSKE in 2026 under a five-year cycle would cause it to coincide with the national and local elections in 2031, potentially leading to yet another postponement, whereas the cycle under Republic Act No. 12326 would coincide with a midterm election only once, in 2043.3 Holding the BSKE in 2027, on the other hand, would conflict with the COMELEC’s preparations for the May 2028 national elections.** Macalintal contends that the reasons offered for Republic: Act No. 12326 fail the test in 2023 Macalintal, which requires that a postponement be justified by reasons “sufficiently important, substantial, or compelling.”*> That, however, is the standard for laws whose primary purpose is to postpone elections. It is not the measure of a term-fixing law. For a term-fixing law, 2025 Macalintal asks whether the period before the new term begins is reasonable and not unduly long. These are considerations of electoral administration that fall squarely within the competence of Congress. They are relevant not because the Court must independently determine whether each is sufficiently compelling to justify a postponement under the 2023 Macalintal guidelines, but because they help explain the transition Congress selected and bear on whether the commencement date is unreasonable or unduly long under 2025 Macalintal. The Court must enforce that constitutional limit without converting its review into a choice among possible electoral calendars. Third, the BSKE is set on a date certain, fixed in the law itself, and every five years thereafter. The electorate knows when it will next vote. This is the opposite of the indefinite deferment that the reasonableness limitation guards against. A fixed date alone does not establish constitutionality; it may still be unreasonable if it arbitrarily or indefinitely postpones voters’ choice of officials. To be more accurate, Republic Act No. 12326 neither leaves the next election to executive discretion nor suspends it until an uncertain event. It sets a date and a recurring interval, which must be assessed under the standard for term-setting iaws clarified in 2025 Macalintai. This allows review of future abuses without treating every electoral-timing change as unconstitutional. Macalintal stresses that, counted from the original December 2025 schedule, the electorate will have waited three years. But the December 2025 date was validly reset by Republic Act No. 12232, as the Court held in 2025 Macalintal. The relevant inauiry under that case is whether the 3 Comment, pp. 29, 33. 34 Id. at 33. % Petition, p. 22.