Sema v. Comelec
Encyclopedia
Sema v. COMELEC
(G.R. No. 177597, 2008) is a court case that was heard before the Supreme Court of the Philippines
. It was consolidated with Marquez v. Comelec (G.R. No. 178628, 2008). It held that the Regional Assembly of the Autonomous Region in Muslim Mindanao
does not have the power to create provinces and cities. Thus, the creation of the province of Shariff Kabunsuan
was unconstitutional and that province no longer exists as a political entity in the Philippines.
, prohibition
, mandamus
and declaratory relief
petitions sought the annulment of Commission on Elections "Resolution No. 7902" (10 May 2007), treating Cotabato City
as part of the legislative district of Shariff Kabunsuan
.
In G.R. No. 177597, Bai Sandra S. A. Sema (Sema), asked the COMELEC "to exclude from the canvassing the votes cast in Cotabato City for representative of the legislative district in question in the Philippine general election, 2007
." In G.R. No. 178628, Perfecto Marquez, asked the Court "to order the COMELEC to conduct a special election for representative of the “First District of Maguindanao with Cotabato City.”
The Ordinance appended to the 1987 Constitution of the Philippines
apportioned 2 legislative districts for Maguindanao
. The first consists of Cotabato City
and 8 municipalities. Maguindanao forms part of the Autonomous Region in Muslim Mindanao
(ARMM), created under its Organic Act
, Republic Act No. 6734 (RA 6734), as amended by Republic Act No. 9054 (RA 9054). Cotabato City, as part of Maguindanao’s first legislative district, is not part of the ARMM but of Region XII (having voted against its inclusion in November 1989 plebiscite).
On 28 August 2006, the ARMM’s legislature, the ARMM Regional Assembly, exercising its power to create provinces under Section 19, Article VI of RA 9054, enacted Muslim Mindanao Autonomy Act No. 201 (MMA Act 201) creating the Province of Shariff Kabunsuan
composed of the 8 municipalities in the first district of Maguindanao.
Later, 2 new municipalities were carved out of the original 9, constituting Shariff Kabunsuan, resulting to total of 11. Cotabato City is not part of Maguindanao. Maguindanao voters ratified Shariff Kabunsuan’s creation in 29 October 2006 plebiscite.
On 6 February 2007, Cotabato City passed Board Resolution No. 3999, requesting the COMELEC to “clarify the status of Cotabato City in view of the conversion of the First District of Maguindanao into a regular province” under MMA Act 201. The COMELEC issued Resolution No. 07-0407 on 6 March 2007 "maintaining the status quo with Cotabato City as part of Shariff Kabunsuan in the First Legislative District of Maguindanao.” Resolution No. 07-0407, adopted the COMELEC’s Law Department recommendation under a Memorandum dated 27 February 2007. The COMELEC issued on 29 March 2007 Resolution No. 7845 stating that Maguindanao’s first legislative district is composed only of Cotabato City because of the enactment of MMA Act 201.
On 10 May 2007, the COMELEC issued Resolution No. 7902 (subject of these cases), amending Resolution No. 07-0407 by renaming the legislative district in question as “Shariff Kabunsuan Province with Cotabato City (formerly First District of Maguindanao with Cotabato City).”
Meanwhile, the Shariff Kabunsuan
creation plebiscite was supervised and officiated by the COMELEC
pursuant to Resolution No. 7727.
The following municipalities seceded from Maguindanao
and formed the new province. All of them were from the first legislative district of Maguindanao.
Kabuntalan was chosen as the capital of the new province. The province was the first to be created under Republic Act No. 9054 or the Expanded ARMM law.
Sandra Sema questioned COMELEC
Resolution 7902 which combined Shariff Kabunsuan and Cotabato City into a single legislative district during the Philippine general election, 2007
. Sema lost to incumbent Congress representative of the Shariff Kabunsuan and Cotabato district, Didagen Dilangalen.
Further, the High Tribunal had to render judgment on "whether COMELEC Resolution No. 7902 is valid for maintaining the status quo in the first legislative district of Maguindanao (as “Shariff Kabunsuan Province with Cotabato City [formerly First District of Maguindanao with Cotabato City]”), despite the creation of the Province of Shariff Kabunsuan out of such district (excluding Cotabato City)."
's 33-page judgment (8-6) penned by Antonio Carpio
annulled
"Muslim Mindanao Autonomy Act 201", which created Shariff Kabunsuan (carved out of Maguindanao
, Autonomous Region in Muslim Mindanao
). Justice Antonio Carpio
opined: "We rule that (1) Section 19, Article VI of RA 9054 is unconstitutional insofar as it grants to the ARMM Regional Assembly the power to create provinces and cities; (2) MMA Act 201 creating the Province of Shariff Kabunsuan is void; and (3) COMELEC Resolution No. 7902 is valid."
Carpio stressed that “only Congress can create provinces and cities because the creation of provinces and cities necessarily includes the creation of legislative districts. Creation of province or a city inherently involves the power to create a legislative district. The Constitution mandates that a province or a city with at least 250,000 inhabitants is entitled to at least one representative."
The Court also declared unconstitutional the RLA’s power to create provinces and cities in the region but it did not pass upon the constitutionality of the creation of new municipalities and barangays. Under Republic Act No. 9140 or the Expanded ARMM Law, the RLA has the power to create new LGUs and to set its own criteria in creating, dividing, merging, or abolishing LGUs.
Carpio further ruled that "in the present 14th Congress, there are 219 district representatives out of the maximum 250 seats in the House of Representatives. Since party-list members shall constitute 20 percent of total membership of the House, there should at least be 50 party-list seats available in every election in case 50 party-list candidates are proclaimed winners. This leaves only 200 seats for district representatives, much less than the 219 incumbent district representatives. Thus, there is a need now for Congress to increase by law the allowable membership of the House, even before Congress can create new provinces."
Consequently, we hold that COMELEC Resolution No. 7902, preserving the geographic and legislative district of the First District of Maguindanao with Cotabato City, is valid as it merely complies with Section 5 of Article VI and Section 20 of Article X of the Constitution, as well as Section 1 of the Ordinance appended to the Constitution."
.
Uncertainty loomed about the legal fate of local elected provincial officials in Shariff Kabunsuan. Among the proclaimed winners in the 2007 local election are 2 board members and the vice governor. Former Sultan Kudarat mayor and 2007 Shariff Kabunsuan gubernatorial candidate Tucao Mastura said: "What will happen to the elected governor, vice governor, and board members? We cannot afford to be under a governor not elected by the people of Shariff Kabunsuan." Rep. Didagen Dilangalen of Shariff Kabunsuan, meanwhile, said "there is a need to declare vacant the position of governor, vice-governor, and board members in new Maguindanao province. There is no election held for the purpose of electing officials in the undivided Maguindanao. The election held there (Maguindanao) is an exercise in futility."
Autonomous Region in Muslim Mindanao
(ARMM) leaders on July 16, 2008 warned that the Court ruling would cause leadership problem and unemployment in the province, for it will cause some of the elected officials and government employees in Shariff Kabunsuan to lose their jobs. Sema v. Comelec reduced the number of provinces in ARMM to 5. ARMM is composed of Maguindanao, Tawi-Tawi, Sulu, Lanao del Sur, Basilan (excluding Isabela City) and the city of Marawi.
Maguindanao Gov. Andal Ampatuan, however, would welcome the judgment, for it reverted to the old province 2 crucial sources of income covered by Shariff Kabunsuan: the Parang seaport and Awang Airport
in Datu Odin Sinsuat.
Shariff Kabunsuan Vice Governor Ibrahim Ibay said that "among those severely affected by the decision are the more than 400 government employees in his province, half of which used to work in the old Maguindanao provincial government. What will happen to them? We dreamed for a separate province and now it is voided."
The ruling may also affect the conduct of August automated election in the region, since Shariff Kabunsuan and Maguindanao are expected to use different kinds of machine for the elections. Maguindanao will use a direct recording electronic technology that uses a touch-screen technology for voting, while Shariff Kabunsuan, along with other ARMM provinces, will use optical mark reader technology, which will require voters to use a paper-based ballot to be fed to a machine.
Commission on Elections (Philippines)
The Commission on Elections, or COMELEC, is one of the three constitutional commissions of the Philippines. Its principal role is to enforce all laws and regulations relative to the conduct of elections, initiatives, referendums, and recalls....
(G.R. No. 177597, 2008) is a court case that was heard before the Supreme Court of the Philippines
Supreme Court of the Philippines
The Supreme Court of the Philippines is the Philippines' highest judicial court, as well as the court of last resort. The court consists of 14 Associate Justices and 1 Chief Justice...
. It was consolidated with Marquez v. Comelec (G.R. No. 178628, 2008). It held that the Regional Assembly of the Autonomous Region in Muslim Mindanao
Autonomous Region in Muslim Mindanao
The Autonomous Region in Muslim Mindanao is the region, located in the Mindanao island group of the Philippines, that is composed of predominantly Muslim provinces, namely: Basilan , Lanao del Sur, Maguindanao, Sulu and Tawi-Tawi. It is the only region that has its own government...
does not have the power to create provinces and cities. Thus, the creation of the province of Shariff Kabunsuan
Shariff Kabunsuan
Shariff Kabunsuan was a province of the Philippines within the Autonomous Region in Muslim Mindanao that existed from 2006 to 2008. The law establishing the province was nullified by the Philippine Supreme Court in 2008.-History:...
was unconstitutional and that province no longer exists as a political entity in the Philippines.
The cases
These consolidated certiorariCertiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
, prohibition
Prohibition
Prohibition of alcohol, often referred to simply as prohibition, is the practice of prohibiting the manufacture, transportation, import, export, sale, and consumption of alcohol and alcoholic beverages. The term can also apply to the periods in the histories of the countries during which the...
, mandamus
Mandamus
A writ of mandamus or mandamus , or sometimes mandate, is the name of one of the prerogative writs in the common law, and is "issued by a superior court to compel a lower court or a government officer to perform mandatory or purely ministerial duties correctly".Mandamus is a judicial remedy which...
and declaratory relief
Declaratory relief
Declaratory relief is a judge's determination of the parties' rights under a contract or a statute, often requested in a lawsuit over a contract. In theory, an early resolution of legal rights will resolve some or all of the other issues in the matter....
petitions sought the annulment of Commission on Elections "Resolution No. 7902" (10 May 2007), treating Cotabato City
Cotabato City
The City of Cotabato is one of the cities of the Philippines located in Mindanao. Cotabato City is an exclave of the SOCCSKSARGEN region found within the boundaries of Maguindanao province, but is independent of that province...
as part of the legislative district of Shariff Kabunsuan
Shariff Kabunsuan
Shariff Kabunsuan was a province of the Philippines within the Autonomous Region in Muslim Mindanao that existed from 2006 to 2008. The law establishing the province was nullified by the Philippine Supreme Court in 2008.-History:...
.
In G.R. No. 177597, Bai Sandra S. A. Sema (Sema), asked the COMELEC "to exclude from the canvassing the votes cast in Cotabato City for representative of the legislative district in question in the Philippine general election, 2007
Philippine general election, 2007
Legislative and local elections were held in the Philippines on May 14, 2007. Positions contested included half the seats in the Senate, which are elected for six-year terms, and all the seats in the House of Representatives, who were elected for three-year terms...
." In G.R. No. 178628, Perfecto Marquez, asked the Court "to order the COMELEC to conduct a special election for representative of the “First District of Maguindanao with Cotabato City.”
The facts
Constitution of the Philippines
The Constitution of the Philippines is the supreme law of the Philippines.The Constitution currently in effect was enacted in 1987, during the administration of President Corazon Aquino, and is popularly known as the "1987 Constitution"...
apportioned 2 legislative districts for Maguindanao
Maguindanao
Maguindanao is a province of the Philippines located in the Autonomous Region in Muslim Mindanao . Its capital is Shariff Aguak. It borders Lanao del Sur to the north, Cotabato to the east, and Sultan Kudarat to the south....
. The first consists of Cotabato City
Cotabato City
The City of Cotabato is one of the cities of the Philippines located in Mindanao. Cotabato City is an exclave of the SOCCSKSARGEN region found within the boundaries of Maguindanao province, but is independent of that province...
and 8 municipalities. Maguindanao forms part of the Autonomous Region in Muslim Mindanao
Autonomous Region in Muslim Mindanao
The Autonomous Region in Muslim Mindanao is the region, located in the Mindanao island group of the Philippines, that is composed of predominantly Muslim provinces, namely: Basilan , Lanao del Sur, Maguindanao, Sulu and Tawi-Tawi. It is the only region that has its own government...
(ARMM), created under its Organic Act
Organic Act
An Organic Act, in United States law, is an Act of the United States Congress that establishes a territory of the United States or an agency to manage certain federal lands. The first such act was the Northwest Ordinance, enacted by the Congress of the Confederation in 1787 in order to create the...
, Republic Act No. 6734 (RA 6734), as amended by Republic Act No. 9054 (RA 9054). Cotabato City, as part of Maguindanao’s first legislative district, is not part of the ARMM but of Region XII (having voted against its inclusion in November 1989 plebiscite).
On 28 August 2006, the ARMM’s legislature, the ARMM Regional Assembly, exercising its power to create provinces under Section 19, Article VI of RA 9054, enacted Muslim Mindanao Autonomy Act No. 201 (MMA Act 201) creating the Province of Shariff Kabunsuan
Shariff Kabunsuan
Shariff Kabunsuan was a province of the Philippines within the Autonomous Region in Muslim Mindanao that existed from 2006 to 2008. The law establishing the province was nullified by the Philippine Supreme Court in 2008.-History:...
composed of the 8 municipalities in the first district of Maguindanao.
Later, 2 new municipalities were carved out of the original 9, constituting Shariff Kabunsuan, resulting to total of 11. Cotabato City is not part of Maguindanao. Maguindanao voters ratified Shariff Kabunsuan’s creation in 29 October 2006 plebiscite.
On 6 February 2007, Cotabato City passed Board Resolution No. 3999, requesting the COMELEC to “clarify the status of Cotabato City in view of the conversion of the First District of Maguindanao into a regular province” under MMA Act 201. The COMELEC issued Resolution No. 07-0407 on 6 March 2007 "maintaining the status quo with Cotabato City as part of Shariff Kabunsuan in the First Legislative District of Maguindanao.” Resolution No. 07-0407, adopted the COMELEC’s Law Department recommendation under a Memorandum dated 27 February 2007. The COMELEC issued on 29 March 2007 Resolution No. 7845 stating that Maguindanao’s first legislative district is composed only of Cotabato City because of the enactment of MMA Act 201.
On 10 May 2007, the COMELEC issued Resolution No. 7902 (subject of these cases), amending Resolution No. 07-0407 by renaming the legislative district in question as “Shariff Kabunsuan Province with Cotabato City (formerly First District of Maguindanao with Cotabato City).”
Meanwhile, the Shariff Kabunsuan
Shariff Kabunsuan
Shariff Kabunsuan was a province of the Philippines within the Autonomous Region in Muslim Mindanao that existed from 2006 to 2008. The law establishing the province was nullified by the Philippine Supreme Court in 2008.-History:...
creation plebiscite was supervised and officiated by the COMELEC
Commission on Elections (Philippines)
The Commission on Elections, or COMELEC, is one of the three constitutional commissions of the Philippines. Its principal role is to enforce all laws and regulations relative to the conduct of elections, initiatives, referendums, and recalls....
pursuant to Resolution No. 7727.
| Option | Votes |
|---|---|
| In favor for creation | 285,372 |
| Against the creation | 8,802 |
The following municipalities seceded from Maguindanao
Maguindanao
Maguindanao is a province of the Philippines located in the Autonomous Region in Muslim Mindanao . Its capital is Shariff Aguak. It borders Lanao del Sur to the north, Cotabato to the east, and Sultan Kudarat to the south....
and formed the new province. All of them were from the first legislative district of Maguindanao.
|
Northern Kabuntalan, Shariff Kabunsuan Northern Kabuntalan is a municipality in the province of Maguindanao, Philippines.It was created out of 11 barangays of Kabuntalan, by virtue of Muslim Mindanao Autonomy Act No. 205, which was subsequently ratified in a plebiscite held on December 30, 2006... |
Kabuntalan was chosen as the capital of the new province. The province was the first to be created under Republic Act No. 9054 or the Expanded ARMM law.
Sandra Sema questioned COMELEC
Commission on Elections (Philippines)
The Commission on Elections, or COMELEC, is one of the three constitutional commissions of the Philippines. Its principal role is to enforce all laws and regulations relative to the conduct of elections, initiatives, referendums, and recalls....
Resolution 7902 which combined Shariff Kabunsuan and Cotabato City into a single legislative district during the Philippine general election, 2007
Philippine general election, 2007
Legislative and local elections were held in the Philippines on May 14, 2007. Positions contested included half the seats in the Senate, which are elected for six-year terms, and all the seats in the House of Representatives, who were elected for three-year terms...
. Sema lost to incumbent Congress representative of the Shariff Kabunsuan and Cotabato district, Didagen Dilangalen.
Issues
The Court was asked to rule on "whether Section 19, Article VI of RA 9054, delegating to the ARMM Regional Assembly the power to create provinces, cities, municipalities and barangays, is constitutional; and if in the affirmative, whether a province created by the ARMM Regional Assembly under MMA Act 201 pursuant to Section 19, Article VI of RA 9054 is entitled to one representative in the House of Representatives without need of a national law creating a legislative district for such province."Further, the High Tribunal had to render judgment on "whether COMELEC Resolution No. 7902 is valid for maintaining the status quo in the first legislative district of Maguindanao (as “Shariff Kabunsuan Province with Cotabato City [formerly First District of Maguindanao with Cotabato City]”), despite the creation of the Province of Shariff Kabunsuan out of such district (excluding Cotabato City)."
Conclusion
On July 16, 2008 the Supreme Court of the PhilippinesSupreme Court of the Philippines
The Supreme Court of the Philippines is the Philippines' highest judicial court, as well as the court of last resort. The court consists of 14 Associate Justices and 1 Chief Justice...
's 33-page judgment (8-6) penned by Antonio Carpio
Antonio Carpio
Antonio T. Carpio is an incumbent Associate Justice of the Supreme Court of the Philippines. He was appointed to the Court by President Gloria Macapagal-Arroyo and assumed office on October 26, 2001, his 52nd birthday.- Profile :...
annulled
"Muslim Mindanao Autonomy Act 201", which created Shariff Kabunsuan (carved out of Maguindanao
Maguindanao
Maguindanao is a province of the Philippines located in the Autonomous Region in Muslim Mindanao . Its capital is Shariff Aguak. It borders Lanao del Sur to the north, Cotabato to the east, and Sultan Kudarat to the south....
, Autonomous Region in Muslim Mindanao
Autonomous Region in Muslim Mindanao
The Autonomous Region in Muslim Mindanao is the region, located in the Mindanao island group of the Philippines, that is composed of predominantly Muslim provinces, namely: Basilan , Lanao del Sur, Maguindanao, Sulu and Tawi-Tawi. It is the only region that has its own government...
). Justice Antonio Carpio
Antonio Carpio
Antonio T. Carpio is an incumbent Associate Justice of the Supreme Court of the Philippines. He was appointed to the Court by President Gloria Macapagal-Arroyo and assumed office on October 26, 2001, his 52nd birthday.- Profile :...
opined: "We rule that (1) Section 19, Article VI of RA 9054 is unconstitutional insofar as it grants to the ARMM Regional Assembly the power to create provinces and cities; (2) MMA Act 201 creating the Province of Shariff Kabunsuan is void; and (3) COMELEC Resolution No. 7902 is valid."
Carpio stressed that “only Congress can create provinces and cities because the creation of provinces and cities necessarily includes the creation of legislative districts. Creation of province or a city inherently involves the power to create a legislative district. The Constitution mandates that a province or a city with at least 250,000 inhabitants is entitled to at least one representative."
The Court also declared unconstitutional the RLA’s power to create provinces and cities in the region but it did not pass upon the constitutionality of the creation of new municipalities and barangays. Under Republic Act No. 9140 or the Expanded ARMM Law, the RLA has the power to create new LGUs and to set its own criteria in creating, dividing, merging, or abolishing LGUs.
Carpio further ruled that "in the present 14th Congress, there are 219 district representatives out of the maximum 250 seats in the House of Representatives. Since party-list members shall constitute 20 percent of total membership of the House, there should at least be 50 party-list seats available in every election in case 50 party-list candidates are proclaimed winners. This leaves only 200 seats for district representatives, much less than the 219 incumbent district representatives. Thus, there is a need now for Congress to increase by law the allowable membership of the House, even before Congress can create new provinces."
Summary
Carpio tersely put the judgment in this manner: "In summary, we rule that Section 19, Article VI of RA 9054, insofar as it grants to the ARMM Regional Assembly the power to create provinces and cities, is void for being contrary to Section 5 of Article VI and Section 20 of Article X of the Constitution, as well as Section 3 of the Ordinance appended to the Constitution. Only Congress can create provinces and cities because the creation of provinces and cities necessarily includes the creation of legislative districts, a power only Congress can exercise under Section 5, Article VI of the Constitution and Section 3 of the Ordinance appended to the Constitution. The ARMM Regional Assembly cannot create a province without a legislative district because the Constitution mandates that every province shall have a legislative district. Moreover, the ARMM Regional Assembly cannot enact a law creating a national office like the office of a district representative of Congress because the legislative powers of the ARMM Regional Assembly operate only within its territorial jurisdiction as provided in Section 20, Article X of the Constitution. Thus, we rule that MMA Act 201, enacted by the ARMM Regional Assembly and creating the Province of Shariff Kabunsuan, is void.Consequently, we hold that COMELEC Resolution No. 7902, preserving the geographic and legislative district of the First District of Maguindanao with Cotabato City, is valid as it merely complies with Section 5 of Article VI and Section 20 of Article X of the Constitution, as well as Section 1 of the Ordinance appended to the Constitution."
Aftermath
The landmark ruling resulted in the Philippines' reverting back to 80 provinces. The ruling also nullified the elections of the governor, vice governor and provincial board of Shariff Kabunsuan and the entire provincial bureaucracy is deemed scrapped as Shariff Kabunsuan reverts back as integral part of MaguindanaoMaguindanao
Maguindanao is a province of the Philippines located in the Autonomous Region in Muslim Mindanao . Its capital is Shariff Aguak. It borders Lanao del Sur to the north, Cotabato to the east, and Sultan Kudarat to the south....
.
Uncertainty loomed about the legal fate of local elected provincial officials in Shariff Kabunsuan. Among the proclaimed winners in the 2007 local election are 2 board members and the vice governor. Former Sultan Kudarat mayor and 2007 Shariff Kabunsuan gubernatorial candidate Tucao Mastura said: "What will happen to the elected governor, vice governor, and board members? We cannot afford to be under a governor not elected by the people of Shariff Kabunsuan." Rep. Didagen Dilangalen of Shariff Kabunsuan, meanwhile, said "there is a need to declare vacant the position of governor, vice-governor, and board members in new Maguindanao province. There is no election held for the purpose of electing officials in the undivided Maguindanao. The election held there (Maguindanao) is an exercise in futility."
Autonomous Region in Muslim Mindanao
Autonomous Region in Muslim Mindanao
The Autonomous Region in Muslim Mindanao is the region, located in the Mindanao island group of the Philippines, that is composed of predominantly Muslim provinces, namely: Basilan , Lanao del Sur, Maguindanao, Sulu and Tawi-Tawi. It is the only region that has its own government...
(ARMM) leaders on July 16, 2008 warned that the Court ruling would cause leadership problem and unemployment in the province, for it will cause some of the elected officials and government employees in Shariff Kabunsuan to lose their jobs. Sema v. Comelec reduced the number of provinces in ARMM to 5. ARMM is composed of Maguindanao, Tawi-Tawi, Sulu, Lanao del Sur, Basilan (excluding Isabela City) and the city of Marawi.
Maguindanao Gov. Andal Ampatuan, however, would welcome the judgment, for it reverted to the old province 2 crucial sources of income covered by Shariff Kabunsuan: the Parang seaport and Awang Airport
Awang Airport
Awang Airport is an airport serving the general area of Cotabato City, located in the province of Maguindanao in the Philippines...
in Datu Odin Sinsuat.
Shariff Kabunsuan Vice Governor Ibrahim Ibay said that "among those severely affected by the decision are the more than 400 government employees in his province, half of which used to work in the old Maguindanao provincial government. What will happen to them? We dreamed for a separate province and now it is voided."
The ruling may also affect the conduct of August automated election in the region, since Shariff Kabunsuan and Maguindanao are expected to use different kinds of machine for the elections. Maguindanao will use a direct recording electronic technology that uses a touch-screen technology for voting, while Shariff Kabunsuan, along with other ARMM provinces, will use optical mark reader technology, which will require voters to use a paper-based ballot to be fed to a machine.
See also
- Autonomous Region in Muslim MindanaoAutonomous Region in Muslim MindanaoThe Autonomous Region in Muslim Mindanao is the region, located in the Mindanao island group of the Philippines, that is composed of predominantly Muslim provinces, namely: Basilan , Lanao del Sur, Maguindanao, Sulu and Tawi-Tawi. It is the only region that has its own government...
- Shariff Kabunsuan creation plebiscite, 2006Shariff Kabunsuan creation plebiscite, 2006The Shariff Kabunsuan creation plebiscite was a plebiscite on the creation of the Province of Shariff Kabunsuan from Maguindanao province in the Philippines. The results were announced on October 31, 2006.Gov. Datu Zaldy Ampatuan of ARMM and his father, Gov...
- Commission on Elections
- Separate Concurring and Dissenting Opinion, J. Tinga
External links
- supremecourt.gov.ph, BAI SANDRA S. A. SEMA versus COMMISSION ON ELECTIONS and DIDAGEN P. DILANGALEN, G.R. No. 177597, & PERFECTO F. MARQUEZ versus COMMISSION ON ELECTIONS, G.R. No. 178628, En Banc, July 16, 2008
- Summary of Voting
- COMELEC Resolution No. 7727, Plebiscite to ratify the creation of the Province of Shariff Kabunsuan