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

Decision 17 G.R. No. E-08557 period before the new term begins is reasonable and not unduly long from the enactment of the law settling the new term. For the reasons stated, it is. Neither is the interval between November 2026 and November 2028 a “badge of the unreasonableness of the interval that may render questionable the genuineness of the reasons for the postponement” under the 2023 Macalintal guidelines.*° The interval must be viewed against the new five-year term. Measured from the October 2023 BSKE, the November 2028 BSKE comes about five years later, the same interval that Congress has prescribed for every BSKE thereafter. The interval is not remote from the term-—it is the term. Nor is the genuineness of the reasons put in doubt considering that they were openly stated and debated in Congress.*” Macalintal also asks what would stop Congress from resetting the BSKE again in 2028, and every time thereafter.>* The answer is the same limitation, which the Court wil! apply to every future law that comes before it. The possibility that a future Congress may abuse its power is not a ground to invalidate the present law. The Court passes upon laws that have been enacted, not upon those that have yet to be filed. VI. Republic Act No. 12326 does not violate substantive due process or the right of suffrage Substantive due process requires the concurrence of two requisites: (1) lawful subject—the interests of the public generally, rather than a particular class, require State interference; and (2) lawful means—the means employed are reasonably necessary to accomplish the objective and are not unduly oppressive.? Both substantive due process requirements are met. The lawful subject is effective local governance: continuity of barangay and SK programs, implementation of multi-year development plans, and efficient use of limited public resources. These matters affect the public, and not just incumbent officials. The chosen means reasonably serve those objectives without being unduly oppressive. Congress set a uniform five-year term and electoral cycle, with transition rules for the new schedule. The legislative record cites development planning, barangays’ limited resources, program continuity, and election costs and administration as the rational bases for this structure. 6 Macalintal v. COMELEC, 943 Phil. 212 (2023) [Per J. Kho, in, En Banc]. Comment, pp. 47-48. Omnibus Motion, p. 5. Mosqueda v. Pilipino Banana Growers & Exparters Association, Inc., et al., 793 Phil. 17, 59 (2016) [Per J. Bersamin, £n Banc].