MANUEL T. DE GUIA, in his capacity as Councilor of the Municipality of Parañaque, Metro Manila, petitioner, vs. HON. COMMISSION ON ELECTIONS, respondent; G.R. No. 104712 May 6, 1992

TOPIC:

Spirit and purpose of the Law

A construction that gives to the language used in a statute a meaning that does not accomplish the purpose for which the statute was enacted should be rejected.

Statutes as a whole

GIST:

RATIONALE: Statutes should be construed in the light of the object to be achieved and the evil or mischief to be suppressed, and they should be given such construction as will advance the object, suppress the mischief, and secure the benefits intended.

A construction should be rejected that gives to the language used in a statute a meaning that does not accomplish the purpose for which the statute was enacted, and that tends to defeat the ends which are sought to be attained by the enactment.

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FACTS:

1. On November 18, 1991, Congress passed RA 7166 "An Act providing for Synchronized National and Local Elections and for Electoral Reforms, Authorizing Appropriations therefor, and for other purposes."

2.   On February 20, 1992, De Guia, an incumbent member (1988 elect) of the Sangguniang Bayan of the Municipality of Parañaque filed with COMELEC a motion for clarification of its Resolution No. 2313 inquiring whether the members of the Sangguniang Bayan of Parañaque and other municipalities of Metro Manila enumerated therein, which are all single-district municipalities would be elected by district in the May 11, 1992 or in the 1995 regular elections.

3. Petitioner filed the instant petition asserting that under par. (d), Sec. 3 of R.A. 7166 the elective members of the Sangguniang Panlungsod and the Sangguniang Bayan, for purposes of the May 11, 1992 regular elections, shall be elected at large in accordance with existing laws. He would include in this class of sanggunian members to be elected at large those of the municipality of Parañaque. 

4. March 3, 1992: COMELEC issued Resolution No. 2379 approving the guidelines submitted by the Provincial Election Supervisors and Municipal Election Registrars concerned pursuant to Resolution No. 2313, and stating therein its purpose in recommending to Congress the districting/apportionment of Sangguniang Panlungsod and Sangguniang Bayan seats, i.e., to reduce the number of candidates to be voted for in the May 11, 1992 synchronized elections. In this Project of Apportionment, Parañaque together with the other twelve (12) municipalities in the Metro Manila Area was divided into two (2) districts with six (6) elective councilors for each district. Its purpose in recommending to Congress the apportionment of Sangguniang Panglungsod and Bayan seats is to reduce the number of candidates to be voted for.

Petitioner: gusto kasama sila at large e 2 districts na sa Paranaque by virtue of Resolution No. 2379

Comelec: yung kasama sa at large mga legislative districts na single district and outside metro manila lang until hindi pa nahahati yung mga ibang legislative districts.

ISSUE:

Whether or Not the Members of the Sangguniang Bayan of Parañaque and other municipalities of Metro Manila enumerated therein, would be elected at large in the May 11, 1992 synchronized/regular elections?

RULING:

NO. Sangguniang Members of Paranaque would NOT be elected AT LARGE but BY DISTRICT in the 11 May 1992 elections.

As stated in Paragraph (c) Section 3, Cities with 2 or more legislative districts ( Manila, Cebu, Davao ) shall continue to be elected by district, as well as the 13 Municipalities of Metro Manila which have already been apportioned into 2 districts.

Paragraph (d) Section 3 of RA 7166 refers only to elective officials of the Sangguniang Panglungsod which are single district cities and Sangguniang Bayan for Municipalities outside Metro Manila, which will remain to be elected at large in the May 11, 1992 election. Once COMELEC apportioned the remaining single districts into several districts, election shall also then be held per district. 

Paragraph (d) should be interpreted in line with the rest of the statute and to follow the interpretation of the petitioner would make the act of the statute in singling out the single district provinces as useless or meaningless. The key to open the door to what the legislature intended in the language of a statute is its purpose or reason which induced it to enact the statute.

The purpose of districting/apportionment of the sanggunian seats is to reduce the number of positions to be voted for in the May 11, 1992, synchronized elections and ensure the efficiency of electoral process.

Statutes should be construed in light of the object to be achieved. A Construction should be rejected that gives the language used in a statute a meaning that does not accomplish its purpose for which it is enacted.

SC ruling: Finding no abuse of discretion, much less grave, on the part of the respondent, and for lack of merit, the instant petition is DISMISSED. No costs.

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LECTURE:

limit the voters, enactment of resolution is in essence, harmonious with Ra 7166 .

ADDITIONAL INFO: