G.R. No. 257427 , June 13, 2023
FLORIDA P. ROBES, PETITIONER, VS. COMMISSION ON ELECTIONS, RESPONDENT.

FACTS

The case involves the interpretation of Republic Act No. 11546 , which reapportioned the Province of Bulacan into six legislative districts. The City of San Jose del Monte, previously a municipality converted into a component city, was historically part of the Fourth Congressional District of Bulacan under Republic Act No. 8797 (2000). This was later amended by Republic Act No. 9230 (2003), granting the city its own representative district. However, RA 11546, enacted in 2021, enumerated the territories comprising the six new legislative districts but was silent on the status of the City of San Jose del Monte, creating an ambiguity as to whether it constituted its own legislative district and was thus entitled to its own representatives in the Sangguniang Panlalawigan.

ISSUE

Whether the legislative history of Republic Act No. 11546 can be examined to resolve the ambiguity regarding the status of the City of San Jose del Monte as a legislative district entitled to Sangguniang Panlalawigan representation.

RULING

Yes. The Separate Concurring Opinion concurs with the ponencia’s use of legislative history as a cardinal rule of statutory construction to ascertain legislative intent when a statute’s language is ambiguous. The opinion agrees that by investigating the legislative history—including earlier related laws, antecedent bills, and transcribed committee deliberations—the Court correctly concluded that the lawmakers’ original intention was to include the lone legislative district of the City of San Jose del Monte as part of the legislative districts of Bulacan Province. Therefore, the City of San Jose del Monte has the right to its own Sangguniang Panlalawigan representatives. The opinion votes to GRANT the petition.