Beruflich Dokumente
Kultur Dokumente
Torres (2005)
Petition: Validity of the suspension from office of
petitioner. Review a resolution of the Executive Secretary
Petitioner: Eduardo Nonato Joson (Governor of Nueva
Ecija)
Respondent: Ruben Torres ( Executive Secretary)
Doctrine:
POWER TO DISCIPLINE LOCAL OFFICIALS
Preventive suspension allows proper investigation.
FACTS:
1. Eduardo Joson, Governor of Nueva Ecija, was charged
with grave misconduct and abuse of discretion.
2. In order to have a loan (P150 Million) approved,
respondents claim that Torres threatened them while in
the session hall for a Sangguniang Panlalawigan
meeting. The loan was later on disapproved for reasons
that were unfavorable to the financial position of the
province since they still had an unpaid obligation.
3. Torres et al, then prayed for Ramos (President) for the
removal or suspension of Joson
4. Ramos then ordered the Secretary of Interior and Local
Government Barbers to take preemptive and
investigative actions, but to not break the peace since
he thinks that the use of force will not be justified.
5. Joson was informed by Sec. Barbers who later on went
to Nueva Ecija to make the parties enter into an
PROVISION:
Article 10 Section 4
The President of the Philippines shall exercise general
supervision over local governments. Provinces with respect
to component cities and municipalities, and cities and
municipalities with respect to component barangays shall
ensure that the acts of their component units are within the
scope of their prescribed powers and functions.
or a constituted Investigating
Committee.
2.
3.
4.
PNO complied with the directive and sent a letter to the OP.
President Estrada directed COA to lift the suspension and
allow payment limited to P100, 000 only.
5.
6.
7.
Petition: Certiorari
Petitioner: Province of Negros Occidental
Respondent: The Commissioners, COA, Regional Cluster Directors
and The Provincial Auditor of Negros Occidental
DOCTRINE:
The Presidents power of general supervision over the LGUs means the
power of a superior officer to see to it that subordinates perform their
functions according to law.
- Limited to seeing to it that rules are followed and laws are faithfully
executed
- President may only point out that rules have not been followed but
the President cannot lay down rules, neither does he have the
discretion to modify or replace rules.
This is different from the Presidents power to control which covers all
executive departments, bureaus and offices.
a.
FACTS:
1.
b.
c.
8.
ISSUE:
WoN COA committed grave abuse of discretion in affirming the
disallowance of P3.76 M for premium paid for the hospitalization
and health care insurance benefits granted by PNO to its 1,949
officials and employees
PROVISION:
A.O. No. 103 (Authorizing the Grant of CY-1993 Productivity
Incentive Benefits to Government Personnel and Prohibiting
Payments of Similar Benefits in Future Years Unless Duly
Authorized by the President
RULING + RATIO:
YES, COA committed grave abuse of discretion in disallowing
premium payment.
Section 2 of A.O. No. 103, which prohibits grant of productivity
incentive benefits to employees, applies ONLY to government
offices/agencies and GOCCs and NOT to LGUs.
LGUs are subject only to the power of supervision of the President and
not to the power of control.
DISPOSITION: The petition is GRANTED.
GAA for the year 2000 provided Internal Revenue Allocations worth
P111, 778,000,000 for Local Government Units
An UNPROGRAMMED FUND heading under the same GAA provided that
P10B shall be allocated outside the P111B state above if it, shall be used to
fund the IRA, which amount shall be released only when the original
revenue targets submitted by the President to Congress can be realized
ISSUES:
1.
PROVISION:
Article X Section 6 of the 1987 Constitution
GAA Headings
XXXVII Allocations to Local Government Units
LIV Unprogrammed Fund
Special Provision under the GAA
EXAMPLES:
Local government units shall have a just share, as determined by law, in the
national taxes which shall be [automatically] released to them as provided by
law, or,
Local government units shall have a just share in the national taxes which shall
be [automatically] released to them as provided by law, or
Local government units shall have a just share, as determined by law, in the
national taxes which shall be automatically released to them subject to
exceptions Congress may provide
2.
Under Article X, Section 6 of the Constitution, only the just share of local
governments is qualified by the words as determined by law, and
not the release thereof, the plain implication is that Congress is not
authorized by the Constitution to hinder or impede the automatic release
of the IRA.
Petition: Certiorari
Petitioner: Benjamin U. Borja
Respondent: Commission on Elections and Jose T. Capco, Jr.
Ponencia: Mendoza, J.
DOCTRINE: (Term Limit of Elective Local Officials)
-
FACTS:
1.
2.
He was then elected mayor of Pateros twice after the term in which
he became mayor due to the death of the incumbent.
3.
4.
5.
ISSUES:
2.
PROVISION:
RULING + RATIO:
1. YES, the Respondent may serve as mayor again.
a. The term limit for elective local officials must be taken
to the right to be elected as well as the right to
serve in the same elective position. Consequently, it
is not enough that an individual has served three
consecutive times, he must also have been elected
to the same position for the same number of times
before the disqualification can apply.
b. It underscores the constitutional intent to cover only
the terms of office to which one may have been
elected for purposes of the three-term limit on local
elective officials, disregarding for this purpose
service by automatic succession.
Disposition: Petition is Dismissed.
On March 9, 2001, Talaga Jr. responded that he was not elected City Mayor
for 3 consecutive terms but only for 2 consecutive terms. He pointed to his
defeat in the 1998 election by Tagarao. Because of his defeat the
consecutiveness of his years as mayor was interrupted, and thus his
mayorship was not for three consecutive terms of 3 years each.
Respondent added that his service from May 12, 2001 until June 30,
2001 for 13 months and 18 days was not a full term.
6.
On April 20, 2001, the COMELEC disqualified Ramon Y. Talaga, Jr. for the
position of city mayor on the ground that he had already served three (3)
consecutive terms, and his CoC was ordered withdrawn and/or cancelled.
7.
8.
9.
FACTS:
1.
Raymundo Adormeo and Ramon Talaga Jr. were the only candidates who
filed their certificates of candidacy for mayor of Lucena City in the May 14,
2001 elections. Talaga Jr. was then the incumbent mayor.
2.
Talaga, Jr. was elected mayor in May 1992 (served full term) then got reelected in 1995-1998. However, in the 1998 election, he lost to Bernard G.
Tagarao.
3.
In the recall election of May 12, 2000, he again won and served the
unexpired term of Tagarao until June 30, 2001.
4.
On March 2, 2001, Adormeo filed with the Office of the Provincial Election
Supervisor, Lucena City a Petition to Deny Due Course to or Cancel
Certificate of Candidacy and/or Disqualification of Ramon Y. Talaga, Jr., on
the ground that Talaga Jr. was elected and had served as city mayor for
three (3) consecutive terms as follows: (1) May 1992 election served full
term; (2) May 1995-1998 election - served full term; (3) May 12, 2000
10. On May 19, 2001, after canvassing, Talaga Jr. was proclaimed as the duly
elected Mayor of Lucena City.
ISSUE: Whether or not Talaga Jr. had already served 3 consecutive terms in
office and is therefore disqualified to run for mayor of Lucena City in the May
14, 2001 elections
PROVISION:
Article 10 Sec. 8. The term of office of elective local officials, except barangay
officials, which shall be determined by law, shall be three years and no such
official shall serve for more than three consecutive terms. Voluntary
renunciation of the office for any length of time shall not be considered as an
interruption in the continuity of his service for the full term for which he was
elected. (Also stated in LGC Sec 43)
RATIO/HELD: No, Talaga Jr. has not served 3 consecutive terms; still qualified
to run for mayor
The term limit for elective local officials must be taken to refer to the right to
be elected as well as the right to serve in the same elective position. It is not
enough that an individual has served three consecutive terms in an elective
local office; he must also have been elected to the same position for the same
number of times before the disqualification can apply (cited in Borja Jr. vs
COMELEC).
The two conditions for the application of the disqualification must concur: a)
that the official concerned has been elected for three consecutive terms in the
same local government post and 2) that he has fully served three consecutive
terms (cited Lonzanida vs. COMELEC).
COMELECs ruling that private respondent was not elected for three (3)
consecutive terms should be upheld. The continuity of his mayorship was
disrupted by his defeat in the 1998 elections, not by voluntary renunciation.
Voluntary renunciation of office for any length of time shall not be considered
as an interruption in the continuity of service for the full term for which he was
elected. Voluntary renunciation of a term does not cancel the renounced term
in the computation of the three term limit; conversely, involuntary severance
from office for any length of time short of the full term provided by law
amounts to an interruption of continuity of service.
Socrates v COMELEC
Socrates vs. Commission on Elections (2002)
Petition: certiorari
Petitioner: VICTORINO DENNIS M. SOCRATES, Mayor of Puerto
Princesa City
Respondent: THE COMMISSION ON ELECTIONS, THE PREPARATORY
RECALL ASSEMBLY (PRA) of Puerto Princesa City, PRA Interim
Chairman Punong Bgy. MARK DAVID HAGEDORN, PRA Interim
Secretary Punong Bgy. BENJAMIN JARILLA, PRA Chairman and
Presiding Officer Punong Bgy. EARL S. BUENVIAJE and PRA Secretary
Punong Bgy. CARLOS ABALLA, JR.
Ponencia: CARPIO, J.
DOCTRINE: Clearly, what the Constitution prohibits is an immediate
reelection for a fourth term following three consecutive terms.
The Constitution, however, does not prohibit a subsequent
reelection for a fourth term as long as the reelection is not
immediately after the end of the third consecutive term.
FACTS:
- 528 members of the barangay officials of the Puerto Princesa
convened for a Preparatory Recall Assembly (PRA) to initiate the recall
of Victorino Dennis M. Socrates as Puerto Princesas mayor. Mark
David M. Hagedorn was designated as interim chair.
- PRA Resolution No. 01-02 declared its loss of confidence in Socrates
and called for his recall. The PRA requested the COMELEC to schedule
the recall election for mayor within 30 days from receipt of the Recall
Resolution. The COMELEC gave due course to the Recall Resolution and
scheduled the recall election on September 7, 2002.
- Edward M. Hagedorn filed his certificate of candidacy for mayor in the
recall election.
Latasa v. COMELEC
Petition: Certiorari
Petitioner: ARSENIO A. LATASA
Respondent: COMMISSION ON ELECTIONS, and ROMEO SUNGA
Ponencia: Azcuna, J.
DOCTRINE: Rest period
FACTS:
6.
7.
8.
9.
PROVISION:
RULING + RATIO:
2.
c.
ISSUE:
1. Whether or not Ongs assumption of office as Mayor of San
Vicente, Camarines Norte from July 1, 1998 to June 30, 2001, may be
considered as one full term service in the context of the consecutive
three-term limit rule.
PROVISIONS:
Section 8, Article X of the 1987 Constitution:
Sec. 8. The term of office of elective local officials, except
barangay officials, which shall be determined by law, shall be
three years and no such official shall serve for more than three
consecutive terms. Voluntary renunciation of the office for any
length of time shall not be considered as an interruption in the
continuity of his service for the full term for which he was elected.
Section 43 (b) of the Local Government Code:
Sec. 43. Term of Office.
(b) No local elective official shall serve for more than three
consecutive years in the same position. Voluntary renunciation of
the office for any length of time shall not be considered an
interruption in the continuity of service for the full term for which
the elective official concerned was elected.
RULING + RATIO:
1. Yes.
It is true that the RTC ruled that it was Alegre who won in
the 1998 mayoralty race and, therefore, was the legally elected mayor
of San Vicente. However, it was without practical and legal use and
value, having been promulgated only after the term of the
contested office has expired.
Petitioners contention that he was only a presumptive
winner in the 1998 mayoralty derby as his proclamation was under
protest did not make him less than a duly elected mayor. His
proclamation by the Municipal Board of Canvassers of San Vicente
as the duly elected mayor in the 1998 mayoralty election coupled by his
assumption of office and his continuous exercise of the functions
thereof from start to finish of the term, should legally be taken as
service for a full term in contemplation of the three-term rule.
It is absurd if Alegre would under the three-term rule - be
considered as having served term 1998-2001, when another
actually served such term.
Disposition:
Petition was DISMISSED and the assailed en banc Resolution
of the COMELEC was AFFIRMED.
.
DIZON v COMELEC
16. Respondent argues that his election for the 1998-2001 post was
not valid as there was a case assailing the validity of his assumption
of office and that the SC declared Anthony Dee as the duly elected
mayor (although the SC found that on this term he was able to
enjoy it fully as de facto mayor, eventually confirmed by the
resolution of the case) and then he was elected mayor again from
2001-2004
a.
DOCTRINE: (Term Limit of Elective Local Officials)
-
b.
c.
FACTS:
14. Petitioner, as citizen and taxpayer, avers that respondent has been
mayor for FOUR terms:
a. 1995-1998
b. 1998-2001
c. 2001-2004
d. 2004-2007
ISSUES:
4.
b.
PROVISION:
RULING + RATIO:
3. YES, the Respondent may serve as mayor again.
a. The law contemplates a rest period or an interruption
of any kind that would constitute as breaking the
three consecutive term limit. The constitution must
be construed in its plain meaning.
i. No matter how short the term of the acting
mayor from 2004-2007 was (two months and
14 days!) it counts as a stop. Thus, the 20042007 occupation of Morales as mayor is void.
ii. INTERESTINGLY: No pronouncements as to
the decisions, administrative orders, and
FACTS:
1. Bolos was elected as Punong Barangay of Barangay
2.
3.
4.
5.
6.
ISSUES:
1. WoN there was voluntary renunciation of the Office of
PROVISIONS:
1. Section 8, Article X
The term of office of elective local officials, except
barangay officials, which shall be determined by
law, shall be three years, and no such official shall
serve for more than three consecutive terms.
Voluntary renunciation of the office for any
length of time shall not be considered as an
interruption in the continuity of his service for
the full term for which he was elected.
2. Section 43 (b) and (c) of the Local Government Code
No local elective official shall serve for more than
three (3) consecutive terms in the same position.
Voluntary renunciation of the office for any
length of time shall not be considered as an
interruption in the continuity of service for the
full term for which the elective official concerned
was elected.
The term of barangay officials and members of
the sangguniang kabataan shall be for five (5)
years, which shall begin after the regular election
of barangay officials on the second Monday of
May 1997: Provided, That the sangguniang
kabataan members who were elected in the May
1996 elections shall serve until the next regular
election of barangay officials.
RULING + RATIO:
1. YES. The Court agrees with COMELEC that there was
voluntary renunciation.
3.
4.
5.
Issue:
WON Asilos preventive suspension constituted an interruption that
allowed him to run for a 4th term.
Provision:
Section 8, Article X of the Constitution
The term of office of elective local officials, except barangay officials,
which shall be determined by law, shall be three years and no such
official shall serve for more than three consecutive terms. Voluntary
renunciation of the office for any length of time shall not be considered
as an interruption in the continuity of his service for the full term for
which he was elected.
Ruling + Ratio:
No, preventive suspension does not interrupt an elective officials
term.
-
2.) Pursuant to RA9333, the next ARMM elections should have been
held on August 8, 2011.
PROVISION:
Section 8, Article X of the Constitution:
Section 8. The term of office of elective local officials, except
barangay officials, which shall be determined by law, shall be three
years and no such official shall serve for more than three consecutive
terms.
Section 7(1), Article VII of RA No. 9054 [Holdover provision]
Section 7. Terms of Office of Elective Regional Officials. (1) Terms of
Office. The terms of office of the Regional Governor, Regional Vice
Governor and members of the Regional Assembly shall be for a period
of three (3) years, which shall begin at noon on the 30 th day of
September next following the day of the election and shall end at noon
of the same date three (3) years thereafter. The incumbent elective
officials of the autonomous region shall continue in effect until their
successors are elected and qualified.
DISPOSITION:
WHEREFORE,
premises
considered,
we DENY with FINALITY the motions for reconsideration for lack
of merit and UPHOLD the constitutionality of RA No. 10153.
It will also affect all the people living the areas of the
mother province and the proposed province
particularly in terms of economy.
Because both the mother province and the proposed
province will be affected, they are, thus, the unit or units
referred to in the Constitution which must be included in
the plebiscite.
o
PROVISION:
Section 3. Art.XI 1973 Constitution
No province, city, municipality, or barrio may be created, divided,
merged, abolished, or its boundary substantially altered, except in
accordance with the criteria established in the local government code,
and subject to the approval by a majority of the votes in a plebiscite in
the unit or units affected.
Section 197. Local Government Code
SEC.197. Requisites for Creation A province may be created if it has a
territory of at least three thousand five hundred square kilometers, a
population of at least five hundred thousand person, an average
estimated annual income, as certified by the Ministry of Finance, of not
less than ten million pesos for the last three consecutive years, and its
creation shall not reduce the population and income of the mother
province or provinces at the time of said creation to less than the
minimum requirements under this section. The territory need not be
contiguous if it comprises two or more islands.
RULING + RATIO:
1. YES. The creation of the province of Negros del Norte
violated the Constitution.
Invalid plebiscite
-
Negros del Norte did not satisfy the area requirement under the
Local Government Code
-
FACTS:
1. Before Senate Bill No. 2157, now R.A. No. 9009, was introduced
by Senator Aquilino Pimentel, there were 57 bills filed for
conversion of 57 municipalities into component cities.
During the 11th Congress (June 1998-June 2001), 33 of these
bills were enacted into law, while 24 remained as pending
bills. Among these 24 were the 16 municipalities that were
converted into component cities through the Cityhood
Laws.
2. RA 9009 amended Section 450 of the LGC which increased
the income requirement solely from locally generated
sources from P20M to P100M to be qualified to become a
component city.
3. The Cityhood Laws direct the COMELEC to hold plebiscites to
determine whether the voters in each respondent municipality
approve of the conversion of their municipality into a city.
4. Petitioners assail the constitutionality of the 16 laws, each
converting the municipality covered thereby into a component
city (Cityhood Laws), and seeking to enjoin the COMELEC
from conducting plebiscites pursuant to the subject laws.
-
5.
RULING + RATIO:
YES. Congress intended that those with pending cityhood bills
during the 11th Congress would not be covered by the new and
higher income requirement of P100 million imposed by R.A. No.
9009. When the LGC was amended by R.A. No. 9009, the
amendment carried with it both the letter and the intent of the
law, and such were incorporated in the LGC by which the
compliance of the Cityhood Laws was gauged.
entered into, the employees that they have already hired, and
the projects that they have already initiated and completed as
component cities. Petitioners have completely overlooked the
need of respondent municipalities to become effective vehicles
intending to accelerate economic growth in the countryside. It
is like the elder siblings wanting to kill the newly-borns so
that their inheritance would not be diminished.
Congress merely took the 16 municipalities covered thereby
from the disadvantaged position brought about by the abrupt
increase in the income requirement of R.A. No. 9009,
acknowledging the privilege that they have already given to
those newly-converted component cities, which prior to the
enactment of R.A. No. 9009, were undeniably in the same
footing or class as the respondent municipalities.
By allowing respondent municipalities to convert into
component cities, Congress desired only to uphold the very
purpose of the LGC, i.e., to make the local government units
enjoy genuine and meaningful local autonomy to enable them
to attain their fullest development as self-reliant communities
and make them more effective partners in the attainment of
national goals, which is the very mandate of the Constitution.
DISPOSITION:
The Motion for Reconsideration of the Resolution dated
August 24, 2010, dated and filed on September 14, 2010 by
respondents Municipality of Baybay, et al. is GRANTED.
The Resolution dated August 24, 2010 is REVERSED and SET
ASIDE. The Cityhood LawsRepublic Acts Nos. 9389, 9390,
9391, 9392, 9393, 9394, 9398, 9404, 9405, 9407, 9408, 9409,
9434,
9435,
9436,
and
9491are
declared
CONSTITUTIONAL.
DOCTRINE:
RULING + RATIO:
NO, RA 9355 is not unconstitutional
When the local government unit to be created consists of one (1)
or more islands, it is exempt from the land area requirement as
expressly provided in Section 442 and Section 450 of the LGC if
the local government unit to be created is a municipality or a
component city, respectively.
countryside development.
The LGC is dynamic and
cognizant of the needs of the Philippines as an archipelagic
country. This accounts for the exemption from the land area
requirement of local government units composed of one or more
islands.
3.
Ponente: Chico-Nazario, J.
DOCTRINE:
MMDA may confiscate and suspend or revoke a drivers license
when a traffic law or regulation has been violated as part of its
mandate to manage transportation and traffic as well as the
administration and implementation of all traffic enforcement
operations, traffic engineering services and traffic education
programs.
4.
5.
FACTS:
NOTE: The facts in numbers 1-4 just set the story. They arent really
relevant because the case was rendered moot and academic. The real
issue at hand is the constitutionality of Sec 5(f) of RA 7924.
1.
2.
ISSUES:
WON Sec 5(f) of RA 7924 is constitutional?
PROVISION:
Sec. 5(f) of RA 7924. Functions and power of MMDA
MMDA shall install and administer a single ticketing system, fix,
impose and collect fines and penalties for all kinds of violations of
traffic rules and regulations, whether moving or nonmoving in nature,
and confiscate and suspend or revoke drivers licenses in the
enforcement of such traffic laws and regulations, the provisions of
Rep. Act No. 4136 and P.D. No. 1605 to the contrary notwithstanding,
and that (f)or this purpose, the Authority shall enforce all traffic laws
and regulations in Metro Manila, through its traffic operation center,
and may deputize members of the PNP, traffic enforcers of local
government units, duly licensed security guards, or members of nongovernmental organizations to whom may be delegated certain
Issues
2.) Pursuant to RA9333, the next ARMM elections should have been
held on August 8, 2011.
Petitioner: DATU FIRDAUSI I.Y. ABBAS, DATU BLO UMPAR ADIONG, DATU
Ponencia: Cortez, J.
DOCTRINE: Section 18 of Article X
xxx
The creation of the autonomous region shall be effective when
approved by majority of the votes cast by the constituent units in a
plebiscite called for the purpose, provided that only the provinces,
cities, and geographic areas voting favorably in such plebiscite shall be
included in the autonomous region.
xxx
FACTS:
This case involves the plebiscite in thirteen (13) provinces and nine (9)
cities in Mindanao and Palawan, scheduled for November 19, 1989, in
implementation of Republic Act No. 6734 or "An Act Providing for an
Organic Act for the Autonomous Region in Muslim Mindanao."
Petitioners pray that the Court:
1) enjoin the Commission on Elections (COMELEC) from conducting the
plebiscite and the Sec. of Budget and Management from releasing funds
for such purpose; (2) declare R.A. No. 6734, or parts thereof,
unconstitutional.
ABBAS v COMELEC(1989)
DOCTRINE:
An autonomous region, as laid out in Article X of the Consitution, cannot
be constituted by only one province/city/municipality
FACTS:
1.
2.
3.
4.
5.
6.
ISSUES:
1.
PROVISION:
RULING + RATIO:
1. NO. The sole province of Ifugao cannot validly constitute
the CAR
a. The keywords provinces, cities, municipalities and
geographical areas in Section 15 of Art X of the
Consitution connote that the region is to be made of
more than one constituent unit. Furthermore, Article
III, Sections 1 and 2 of Aa 6766 provide that the CAR is
to be administered by the Cordillera government
consisting of the Regional Government and local
government units. From these sections, it can be
gleaned that Congress never intended that a single
province may constitute the autonomous region.
b. Article V, Sections 1 and 4 of the statute vests the
legislative power in the Cordillera Assembly. If the
position of the respondents is taken, there will be the
awkward situation of legislative power being
concurrently held by the Cordillera Assembly of the
c.
d.
e.
BADUA V CA
Ponencia: J, PUNO.
DOCTRINE
Since the CAR did not come into legal existence, the Maeng
Tribal Court was not constituted into an indigenous or special
court under R.A. No. 6766.Hence, the Maeng Tribal Court is
an ordinary tribal court existing under the customs and
traditions of an indigenous cultural community.
Such tribal courts are not a part of the Philippine judicial
system which consists of the Supreme Court and the lower
courts which have been established bylaw. They do not possess
judicial power. Like the pangkats or conciliation panels created
by P.D. No.1508 in the barangays, they are advisory and
conciliatory bodies whose principal
objective is to
bring
together the parties to a dispute and persuade them to make
peace, settle, and compromise.
FACTS:
PROVISION:
Section 18. The Congress shall enact an organic act for each
autonomous region with the assistance and participation of the
regional consultative commission composed of representatives
appointed by the President from a list of nominees from multisectoral bodies. The organic act shall define the basic structure of
government for the region consisting of the executive department
and legislative assembly, both of which shall be elective and
representative of the constituent political units. The organic acts shall
likewise provide for special courts with personal, family, and property
law jurisdiction consistent with the provisions of this Constitution and
national laws.
The creation of the autonomous region shall be effective when
approved by majority of the votes cast by the constituent units in a
plebiscite called for the purpose, provided that only provinces, cities,
and geographic areas voting favorably in such plebiscite shall be
included in the autonomous region.
Section 19. The first Congress elected under this Constitution shall,
within eighteen months from the time of organization of both Houses,
pass the organic acts for the autonomous regions in Muslim
Mindanao and the Cordilleras.
DISPOSITION:
Reasoning: