G.R. No. 89651 and G.R. No. 89965 November 10, 1989
DATU FIRDAUSI I.Y. ABBAS, ET AL., and ATTY. ABDULLAH D. MAMA-O, petitioners, vs. COMMISSION ON ELECTIONS and HON. GUILLERMO C. CARAGUE, respondents.

FACTS

These consolidated petitions sought to enjoin the plebiscite scheduled for November 19, 1989, for the ratification of Republic Act No. 6734 , the Organic Act for the Autonomous Region in Muslim Mindanao (ARMM), and to declare the law unconstitutional. Petitioners, representing taxpayers and constituents in Mindanao, argued that R.A. No. 6734 violated the 1987 Constitution and conflicted with the 1976 Tripoli Agreement between the Philippine government and the Moro National Liberation Front. They contended the law did not comply with constitutional mandates for autonomy and improperly deviated from the terms of the international agreement.
The Constitution, under Article X, mandates Congress to enact an organic act for autonomous regions in Muslim Mindanao and the Cordilleras. Pursuant to this, Congress passed R.A. No. 6734 . Petitioners specifically challenged provisions they claimed infringed upon the constitutional grant of legislative powers to the autonomous region and argued that the law’s effectivity, contingent upon the organization of an Oversight Committee, was unconstitutional. They also asserted that the Tripoli Agreement, as a binding international accord, should prevail over the allegedly inconsistent provisions of the organic act.

ISSUE

The primary issues were: (1) Whether R.A. No. 6734 , or parts thereof, is unconstitutional for violating the provisions of the 1987 Constitution on autonomous regions; and (2) Whether alleged conflicts between R.A. No. 6734 and the Tripoli Agreement render the law invalid.

RULING

The Supreme Court dismissed the petitions, upholding the constitutionality of R.A. No. 6734 . On the issue of the Tripoli Agreement, the Court found it unnecessary to rule on its binding nature under international or domestic law. The standard for evaluating the organic act is the 1987 Constitution itself, which provides the framework for creating the autonomous region. Any alleged conflict with the Tripoli Agreement is immaterial, as the constitutional provisions control. The Constitution is the supreme law, and the organic act must conform to it, not to a prior political agreement.
Regarding the constitutional challenges, the Court applied the presumption of constitutionality, emphasizing that petitioners failed to clearly overcome this presumption. The Court found no merit in the claim that the law infringed on the legislative powers granted to the autonomous region by the Constitution. The provisions of R.A. No. 6734 were deemed to operate within the constitutional framework. Furthermore, the Court ruled that the law’s effectivity clause was not unconstitutional. The organization of the Oversight Committee was intended to ensure a smooth transition and did not impede the operation of the Organic Act. The plebiscite mechanism itself was in strict compliance with the constitutional requirement that the creation of the autonomous region be approved by a majority vote in the constituent units. Consequently, the Court found no basis to enjoin the plebiscite or invalidate the law.