The Supreme Court struck down the cityhood laws for sixteen municipalities, underscoring that laws creating cities must adhere strictly to the criteria outlined in the Local Government Code. This decision protects the financial stability of existing cities by preventing municipalities that do not meet the required income standards from becoming cities and subsequently drawing from the Internal Revenue Allotment (IRA). This ruling ensures a more equitable distribution of national taxes and upholds the constitutional mandate that all criteria for city creation be uniformly applied.

When Dreams of Cityhood Clash with Constitutional Mandates

At the heart of this case is the question of whether Congress can exempt certain municipalities from the income requirements set forth in the Local Government Code for cityhood. The League of Cities of the Philippines (LCP) argued that the cityhood laws, which converted sixteen municipalities into cities, violated Section 10, Article X of the Constitution, which mandates that the creation of local government units must follow the criteria established in the Local Government Code. The LCP further contended that these laws violated the equal protection clause, as they unfairly favored the respondent municipalities.

The respondent municipalities, on the other hand, asserted that they were merely benefiting from the intent of Republic Act No. 9009 (RA 9009), which amended Section 450 of the Local Government Code by increasing the annual income requirement for conversion of a municipality into a city from P20 million to P100 million. They argued that since their cityhood bills were pending before the enactment of RA 9009, they should be exempt from the increased income requirement. This legal battle highlighted the tension between the aspirations of municipalities seeking cityhood and the constitutional principles ensuring fair and uniform application of laws.

The Supreme Court sided with the LCP, declaring the cityhood laws unconstitutional. The Court emphasized that Section 10, Article X of the Constitution is explicit: the creation of local government units must adhere to the criteria established in the Local Government Code, not in any other law. To allow otherwise would undermine the uniformity and fairness intended by the Constitution. The Court found that the Cityhood Laws explicitly exempted respondent municipalities from the increased income requirement in Section 450 of the Local Government Code, as amended by RA 9009, which directly violated Section 10, Article X of the Constitution.

Further, the Court addressed the argument that the cityhood laws were merely implementing the intent of RA 9009, stating that Congress could have included an exemption in RA 9009 but chose not to. Thus, the intended exemption must be written into the Local Government Code. In reaching this conclusion, the Court stated,

Congress cannot create a city through a law that does not comply with the criteria or exemption found in the Local Government Code.

This clarified the parameters within which Congress could act concerning the creation of local government units.

Building on this principle, the Court also considered whether the cityhood laws violated the equal protection clause. The equal protection clause dictates that all persons similarly situated should be treated alike. Even if the exemption provision were written in Section 450 of the Local Government Code, the Court reasoned, it would still be unconstitutional for violating the equal protection clause. The Court clarified that there was no valid classification because the exemption would be based solely on the fact that the municipalities had cityhood bills pending when RA 9009 was enacted. This emphasis affirmed the constitutional requirement that laws treat similarly situated entities in the same manner.

Finally, the Court explained that the Cityhood Laws violate Section 6, Article X of the Constitution because they prevent a fair and just distribution of national taxes to local government units. By not following the income criterion prescribed in Section 450 of the Local Government Code, as amended by RA 9009, the Cityhood Laws compromise the equitable distribution of the Internal Revenue Allotment (IRA). In practical terms, a city with an annual income of only P20 million should not receive the same share in national taxes as a city with an annual income of P100 million or more. Therefore, the decision ultimately upholds the constitutional principles of local government creation, ensuring equitable distribution of national resources.

FAQs

What was the central legal question in this case?	Whether the cityhood laws violated Section 10, Article X of the Constitution, which requires adherence to criteria established in the Local Government Code for creating cities.
What is Republic Act No. 9009 (RA 9009)?	RA 9009 amended Section 450 of the Local Government Code, increasing the annual income requirement for a municipality to become a city from P20 million to P100 million.
What did the League of Cities of the Philippines (LCP) argue?	The LCP argued that the cityhood laws violated the Constitution and the equal protection clause by exempting certain municipalities from the income requirement.
What did the respondent municipalities argue?	They argued that they should be exempt from RA 9009’s increased income requirement because their cityhood bills were pending before it was enacted.
What was the Supreme Court’s ruling?	The Supreme Court ruled that the cityhood laws were unconstitutional, as they did not adhere to the criteria set forth in the Local Government Code and violated the equal protection clause.
What does Section 10, Article X of the Constitution say?	It mandates that the creation of local government units must follow the criteria established in the Local Government Code, subject to voter approval in a plebiscite.
Why did the Court say the laws violated the equal protection clause?	Because the exemption was based solely on the fact that certain municipalities had pending cityhood bills, without a valid or rational basis for distinguishing them.
What is the practical effect of this ruling?	The ruling protects the financial stability of existing cities and ensures a more equitable distribution of national taxes.

In conclusion, this case reinforces the importance of adhering to the constitutional requirements for local government creation and prevents the erosion of resources available to established cities. The Supreme Court’s decision underscores the need for clear, uniform, and non-discriminatory criteria for cityhood, safeguarding the financial health and stability of local governments throughout the Philippines.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: League of Cities vs. COMELEC, G.R. No. 176951, November 18, 2008