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

Decision 18 GR. No. E-08557 The proposed arrangement, i.e., hoiding the November 2026 BSKE and applying the five-year term prospectively, does not make the enacted arrangement constitutionally unreasonable. It is reiterated that the Constitution does not require Congress to choose the least disruptive option. The Court must assess whether the chosen means are constitutionally permissible, not whether they are optimal policy. We find that the objectives and means are sufficiently related, and petitioner has not shown the law to be unduly oppressive or arbitrary. The law itself provides that the unexpended balance of the appropriations for the BSKE shall be deemed a continuing appropriation of the COMELEC, available for the preparatory activities for the 2028 National and Local Elections.*° Congress. considered terms ranging from three to 10 years,. heard the Liga ng mga Barangay, the Department of Interior and Local Government, and. the National Youth Commission, and considered and rejected the alternative of holding the 2026 BSKE and applying the five-year. term only to those elected then.*! The means chosen, a uniform five-year term implemented through an election cycle that begins in 2028, bear a reasonable relation to these ends. The fact that Congress considered and rejected the alternative of holding the November 2026 BSKE and applying the five-year term only to those. elected thereafter does not establish that the transition it ultimately adopted is arbitrary. The alternative would have preserved the existing election date, but it would also have required Congress to retain a different transition arrangement and to begin the new electoral cycle with officials elected under the former schedule. There is no constitutional command, whether express or implied, for Congress to select the alternative merely because it would avoid moving the next election. It bears stressing that the relevant question that remains is whether the means chosen bear a reasonable relation to the legitimate purposes of the law and are not unduly oppressive, and not whether another arrangement would have been jess disruptive in one respect. Congress could consider continuity in local development planning, the costs and logistics of separate elections, and the need for a uniform and predictable electoral cycle. However, these considerations do not conclusively establish that every feature of Republic Act No. 12326 is valid, but they are sufficient to distinguish a debatable legislative choice from a measure shown to be constitutionally arbitrary. The absence of a study showing the inadequacy of the former four- year term does not make the new five-year term unconstitutional. Congress 40 Republic Act No. 12326, sec. 7. “1 Comment, pp. 3, 14-15. .