G.R. No. L-18684. September 14, 1961.
Lamberto Macias, Lorenzo Teves, Fausto Dugenio, Rogaciano Mercado and Mariano Perdices, petitioners, vs. The Commission on Elections and Vicente Gella in his Capacity as National Treasurer, respondents.

FACTS

Petitioners, comprising four members of the House of Representatives and a provincial governor, sought to enjoin the implementation of Republic Act No. 3040, which apportioned legislative districts. They alleged the law was unconstitutional for three reasons: it was passed without printed final copies being furnished to House members three days prior, as constitutionally required; it was enacted more than three years after the last census return; and it violated the constitutional mandate for proportional representation by creating districts without proper regard to population.
Respondents, including the Commission on Elections and the National Treasurer, defended the law’s constitutionality. They argued petitioners lacked legal standing, asserted the enrolled bill doctrine created a presumption of constitutional enactment, and contended the apportionment was based on a November 1960 census report and complied with proportional representation.

ISSUE

The primary issue was whether Republic Act No. 3040 was unconstitutional for violating the constitutional principle of proportional representation in the apportionment of legislative districts.

RULING

The Supreme Court declared Republic Act No. 3040 unconstitutional and void. The Court first established that petitioners had legal standing to sue. As voters and officials from provinces allegedly deprived of proper representation (e.g., Misamis Oriental, Negros Oriental, Bulacan), they possessed a sufficient interest to challenge a statute that impaired their right to an effective elective franchise.
On the substantive issue, the Court found the Act a clear violation of the constitutional mandate for apportionment based on inhabitants. The law created glaring inequalities: it allotted Cebu seven representatives while Rizal, with a larger population, received only four; it gave Manila four representatives while Cotabato, with a larger population, received only three. Specific comparisons showed Misamis Oriental (387,839 inhabitants) was granted one district, while Cavite (379,902) received two; Negros Oriental (598,783) and Bulacan (557,691) were allotted two districts each, while Albay (515,961) received three. This disproportionality transgressed the fundamental principle of equality of representation, which is essential to a republican form of government.
The Court held that the constitutionality of an apportionment act is a judicial question. The judiciary has the duty to intervene when a constitutional limitation is infringed, notwithstanding the political nature of the subject. The Court deemed it unnecessary to rule definitively on the other alleged defects (the three-day printed copy rule and the three-year period after the census) since the disproportionality alone was sufficient to invalidate the statute. The injunction against the law’s implementation was made permanent.