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Romulo B. Macalintal v. Office of the President, et al. — Decision — Official PDF
G.R. No. E-08557 — Promulgated October 14, 2026 · 2026 · Supreme Court 2026 / Decision or signed resolution
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Decision 19 G.R. No. E-08557
need not wait for an existing law to prove itself deficient before revising it.
Indeed, legislatures may change policy based on experience, institutional
priorities, or their view of the public interest, subject to constitutional limits.
Macalintal’s challenge to these reasons is a disagreement with their
wisdom. He argues that the reasons given at a media briefing are frivolous,
that no study examined the sufficiency of the four-year term, and that the
oil crisis and conflicts abroad cannot justify a postponement.”
However, the validity of a law is measured against the purposes
reflected in its text and in the legislative record, not against a
spokesperson’s remarks at a media briefing. The record shows that the
Senate committee reviewed studies on the economic effects of longer local
terms,” and the Constitution does not condition the exercise of legislative
power on the completion of any particular study. As to the oil crisis, the
House sponsor himself treated it as secondary, stating that “[t]he price of
oil goes up and down. The barangays’ need for time does not.”“
One may find these reasons persuasive or find them wanting.
Reasonable minds may differ. Yet the Court may not strike down a law
because it would have struck the balance differently. It is precisely because
Article X, Section 8 of the Constitution commits the term of barangay
officials to Congress that the choice between a four-year and a five-year
term, and between applying the new term to the incumbents or only to their
successors, belongs to Congress.
We may disagree with the reasons of Congress, but it is not for the
Court to replace them with its own. :
To require compelling reasons for the length of the term would be to
apply a standard drawn from the 2023 Macalintal guidelines on the
postponement of elections. Nothing in Article X, Section 8 of the
Constitution requires Congress to justify the length of the term it chooses
with compelling reasons, or to first test the existing term or conduct an
empirical study before changing it. The Constitution leaves the term of
barangay officials to be “determined by law.” The question under the due
process clause is whether the interests of the public require the measure,
and whether the means employed are reasonably necessary to its purpose
and not unduly oppressive.
Neither does Republic Act No. {2326 infringe the right of suffrage.
The Court held in 2025 Macalintal that the right of suffrage “does not
mandate any specific ‘electoral frequency or term length for the BSK
officials,” and that an election is regular “if it occurs at fixed, predictable
® Petition, pp. 2-7, 17-19.
3 Comment, p. 28.
“4 Id.at4.
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