G.R. No. 100318 , 100308, 100417, 100420; July 30, 1991
Governor Emilio M.R. Osmeña, et al., vs. Commission on Elections, et al.

FACTS

Petitioners, including provincial governors and members of the House of Representatives, filed suits challenging the constitutionality of Republic Act No. 7056 . This law, enacted on June 20, 1991, provided for the holding of national elections (for President, Vice-President, and Senators) on the second Monday of May 1992, but postponed the local elections (for provincial, city, and municipal officials) to the second Monday of November 1992. It further authorized synchronized elections to begin in 1995 and contained a hold-over provision allowing incumbent local officials to remain in office until their successors were elected and qualified in November.
Petitioners argued that RA 7056 violated the explicit constitutional mandate for synchronized national and local elections. They contended that the 1987 Constitution , particularly its Transitory Provisions, required the election of all officials—President, Vice-President, Senators, Members of the House of Representatives, and local officials—to be held simultaneously on the second Monday of May 1992. They asserted that the legislative act, by desynchronizing the elections, contravened this clear directive and that the hold-over provision and the resultant shortening of terms for newly elected local officials were likewise unconstitutional.

ISSUE

Whether Republic Act No. 7056 is unconstitutional for violating the synchronization of elections as mandated by the 1987 Constitution .

RULING

Yes, the Supreme Court declared RA 7056 unconstitutional and void. The Court anchored its ruling on the plain and unequivocal language of the Constitution. Section 2, Article XVIII (Transitory Provisions) states that the election of the President, Vice-President, Senators, Members of the House of Representatives, and local officials shall be “synchronized” and held simultaneously. The Court emphasized that the term “synchronize” means to cause events to agree in time or to happen at the same time.
The constitutional intent was clear: to hold all these elections together on the second Monday of May 1992. By legislating a separate date for local elections seven months later, Congress effectively desynchronized the electoral process, directly contravening the constitutional command. The Court rejected the government’s arguments about logistical difficulties, stating that such practical problems could not justify a departure from a constitutional mandate. The correct recourse for addressing such issues, if insurmountable, would be through the constitutional amendment process, not through ordinary legislation that ignores a fundamental provision.
Consequently, the postponement of local elections, the hold-over provision for incumbents, and the resultant alteration of terms of office all stemmed from this unconstitutional desynchronization and were likewise invalidated. The Court made permanent the restraining order against the implementation of RA 7056.