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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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SCANNED TEXT · CHECK ORIGINAL WORDING · DIGITAL P. 9 / 33
Decision 5 GR. No. E-08557
5. Whether the November 2028 date set by Republic Act No. 12326
is reasonable and not unduly long:
6. Whether Republic Act No. 12326 violates substantive due process
and the right of suffrage;
7. Whether the hold-over of incumbent barangay officials under
Republic Act No. 12326 constitutes a legislative appointment;
8. Whether Republic Act No. 12326 violates the one subject-one title
rule under Article VI, Section 26(1) of the Constitution; and
9. Whether Macalintal is entitled to the issuance of a TRO, SQAO,
and/or WPI.
Ruling of the Court
The Petition lacks merit. Larida’s intervention must likewise be
denied. The Court resolves the issues in the order presented above.
I. Direct resort to the Court is justified,
and the requisites for the exercise of
judicial review are present
Respondents argue that the Petition violates the doctrine of hierarchy
of courts because it raises factual issues, such as the alleged waste of public
funds, the public’s opposition to the postponement, and the alleged lack of
study supporting the law.!”
The Court does not agree.
Direct resort to tne Court is allowed when the issues raised are pure
questions of law.'* The constitutional questions in this case are of that kind.
Whether Republic Act No. 12326 is a term-fixing law, whether it infringes
the right of suffrage, whether its hold-over provision amounts to a
legislative appointment, and whether it complies with the one subject-one
title rule may all be resolved on the basis of the text of the law, the
undisputed legislative record, and prevailing jurisprudence. The factual
matters that respondents identify are not essential to the resolution of these
questions. As in 2025 Macaiintal, the Court can resolve whether the
assailed law is unconstitutional without presenting evidence.
' Comment, pp. 9-10.
18 Macalintal v. Senate of the Philippines, G.R. Nos. 8-02002. B-02010, E-02142 & E-02276, November
11, 2025 [Per J. J. Lopez, Ex Banc}.
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