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

Decision 26 G.R. No. E-08557 enactment of the law setting the new term of office.’ The Court likewise held that the right of suffrage “guarantees that citizens will elect their officials through regular elections—it does not mandate any- specific electoral frequency or term length for the BSK officials,” and that “[a]n election is ‘regular’ if it occurs at fixed, predictable intervals established by law, regardless of whether those intervals are two, three, four, or five 2760 . years. Measured against these pronouncements, a claimed right to an election on a particular statutory date (one that Congress has since reset under its express constitutional authority) is not a right iz esse. At the very least, it is a right in serious dispute. The issue at hand is not whether petitioner has a constitutional right to suffrage. Rather, the issue is whether petitioner has a clear legal right to compel the BSKE to be held specifically in November 2026, notwithstanding the subsequent enactment of Republic Act No. 12326. We find that he does not. i, 2025 ° Macalintal renders petitioners claimed right, at the very least, doubtful In 2025 Macalintal, the Court held that Republic Act No. 12232 isa term-setting law, and that “since Republic Act No. 12232 is not primarily an election postponement law, the [2023] Macalinial guidelines become inapplicable.” *! The Court explained that “[t]he legal character of the measure determines which constitutional framework governs its validity,” and that guidelines “formulated to govern laws whose primary purpose is postponing elections...should not apply to laws whose primary purpose is constitutional term-setting, even if it incidentally affects the date of elections.”° On its face, Republic Act No. 12326 is a law of the same-kind. Its title is “An Act Fixing the Term of Office of Barangay Officials and Members of the Sangguniang Kabataan to Five [] Years, Amending Republic Act No. 12232.” Its first section fixes a five-year term;© its 59 Macalintal v. Senate of the Philippines, G.R. Nos. E-02002, E-02010, E-02142 & E-02276, November 11, 2025 [Per J. Lopez, J., En Banc}. 6 Id. id. & Id. %& SECTION 1. Section 1 of Republic Act No. 12232 or “An Act Setting the Term of Office of Barangay Officiais and Members of the Sanggunianz’ Kabataan, and for Other Purposes” is hereby amended to read as follows: “SECTION 1. Term of Office. — The ierm of office of all barangay and Sangguniang Kabataan officials shall be five {] years. No elective barangay 0! shall serve for more than two [] consecutive terms in the same position. No elective Sang: 2 Kabataan efficiai shall serve for more than one [] term in the same position. Voluntary-rer i Of 5! for any length of time shali not be considered