National Economy, Patrimony and Ammendment Cases

7/27/2019 National Economy, Patrimony and Ammendment Cases

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Tanada vs Angara, 272 SCRA 18, May 2, 1997

Facts : This is a petition seeking to nullify the Philippine ratification of the World

Trade Organization (WTO) Agreement. Petitioners question the concurrence of

herein respondents acting in their capacities as Senators via signing the said

agreement.

The WTO opens access to foreign markets, especially its major trading partners,

through the reduction of tariffs on its exports, particularly agricultural and industrial

products. Thus, provides new opportunities for the service sector cost and

uncertainty associated with exporting and more investment in the country. These

are the predicted benefits as reflected in the agreement and as viewed by the

signatory Senators, a free market espoused by WTO.

Petitioners on the other hand viewed the WTO agreement as one that limits,

restricts and impair Philippine economic sovereignty and legislative power. That the

Filipino First policy of the Constitution was taken for granted as it gives foreigntrading intervention.

Issue : Whether or not there has been a grave abuse of discretion amounting to

lack or excess of jurisdiction on the part of the Senate in giving its concurrence of

the said WTO agreement.

Held: In its Declaration of Principles and state policies, the Constitution adopts the

generally accepted principles of international law as part of the law of the land, and

adheres to the policy of peace, equality, justice, freedom, cooperation and amity ,

with all nations. By the doctrine of incorporation, the country is bound by generallyaccepted principles of international law, which are considered automatically part of

our own laws. Pacta sunt servanda international agreements must be performed in

good faith. A treaty is not a mere moral obligation but creates a legally binding

obligation on the parties.

Through WTO the sovereignty of the state cannot in fact and reality be considered

as absolute because it is a regulation of commercial relations among nations. Such

as when Philippines joined the United Nations (UN) it consented to restrict its

sovereignty right under the concept of sovereignty as autolimitation. What Senate

did was a valid exercise of authority. As to determine whether such exercise is wise,

beneficial or viable is outside the realm of judicial inquiry and review. The act ofsigning the said agreement is not a legislative restriction as WTO allows withdrawal

of membership should this be the political desire of a member. Also, it should not be

viewed as a limitation of economic sovereignty. WTO remains as the only viable

structure for multilateral trading and the veritable forum for the development of

international trade law. Its alternative is isolation, stagnation if not economic self-

destruction. Thus, the people be allowed, through their duly elected officers, make


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their free choice.

Petition is DISMISSED for lack of merit.

Miners Association of the Philippines v. Factoran, Case Digest

G.R. No. 98332 January 16, 1995

Facts :

Former President Corazon Aquino issued Executive Order Nos 211 and 279 in the

exercise of her legislative powers. EO No. 211 prescribes the interim procedures in

the processing and approval of applications for the exploration, development andutilization of minerals pursuant to Section 2, Article XII of the 1987 Constitution. EO

No. 279 authorizes the DENR Secretary to negotiate and conclude joint-venture, co-

production, or production- sharing agreements for the exploration, development,

and utilization of mineral resources.

The issuance and the impeding implementation by the DENR of Administrative

Order Nos. 57 which declares that all existing mining leases or agreements which

were granted after the effectivity of the 1987 Constitutionshall be converted into

production-sharing agreements within one (1) year from the effectivity of these

guidelines. and Administrative Order No. 82 which provides that a failure to submit

Letter of Intent and Mineral Production-Sharing Agreement within 2 years from the

effectivity of the Department Administrative Order No. 57 shall cause the

abandonment of the mining, quarry, and sand and gravel claims, after their

respective effectivity dates compelled the Miners Association of the Philippines, Inc.,

an organization composed of mining prospectors and claim owners and claim

holders, to file the instant petition assailing their validity and constitutionality

before this Court.

Issue :

Are the two Department Administrative Orders valid?

Ruling :

Yes. Petitioner's insistence on the application of Presidential Decree No. 463, as

amended, as the governing law on the acceptance and approval of declarations of

location and all other kinds of applications for the exploration, development, and

utilization of mineral resources pursuant to Executive Order No. 211, is erroneous.


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Presidential Decree No. 463, as amended, pertains to the old system of exploration,

development and utilization of natural resources through "license, concession or

lease" which, however, has been disallowed by Article XII, Section 2 of the 1987

Constitution. By virtue of the said constitutional mandate and its implementing law,

Executive Order No. 279 which superseded Executive Order No. 211, the provisions

dealing on "license, concession or lease" of mineral resources under PresidentialDecree No. 463, as amended, and other existing mining laws are deemed repealed

and, therefore, ceased to operate as the governing law. In other words, in all other

areas of administration and management of mineral lands, the provisions of

Presidential Decree No. 463, as amended, and other existing mining laws, still

govern. Section 7 of Executive Order No. 279 provides, thus:

Sec. 7. All provisions of Presidential Decree No. 463, as amended, other existing

mining laws, and their implementing rules and regulations, or parts thereof, which

are not inconsistent with the provisions of this Executive Order, shall continue in

force and effect.

Well -settled is the rule, however, that regardless of the reservation clause, mining

leases or agreements granted by the State, such as those granted pursuant to

Executive Order No. 211 referred to this petition, are subject to alterations through

a reasonable exercise of the police power of the State.

Accordingly, the State, in the exercise of its police power in this regard, may not be

precluded by the constitutional restriction on non-impairment of contract from

altering, modifying and amending the mining leases or agreements granted under

Presidential Decree No. 463, as amended, pursuant to Executive Order No. 211.

Police Power, being co-extensive with the necessities of the case and the demands

of public interest; extends to all the vital public needs. The passage of Executive

Order No. 279 which superseded Executive Order No. 211 provided legal basis forthe DENR Secretary to carry into effect the mandate of Article XII, Section 2 of the

1987 Constitution.

WHEREFORE, the petition is DISMISSED for lack of merit.

La Bugal-B'Laan Tribal Assn vs Ramos Case Digest

G.R. No 127882

Facts :

On July 25, 1987, then President Corazon C. Aquino issued Executive Order (E.O.)

No. 2796 authorizing the DENR Secretary to accept, consider and evaluate

proposals from foreign-owned corporations or foreign investors for contracts or

agreements involving either technical or financial assistance for large-scale

exploration, development, and utilization of minerals, which, upon appropriate


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recommendation of the Secretary, the President may execute with the foreign

proponent.

On March 3, 1995, then President Fidel V. Ramos approved R.A. No. 7942 to "govern

the exploration, development, utilization and processing of all mineral resources."

R.A. No. 7942 defines the modes of mineral agreements for mining operations,outlines the procedure for their filing and approval, assignment/transfer and

withdrawal, and fixes their terms. Similar provisions govern financial or technical

assistance agreements.

On April 9, 1995, 30 days following its publication on March 10, 1995 in Malaya and

Manila Times, two newspapers of general circulation, R.A. No. 7942 took effect.

Shortly before the effectivity of R.A. No. 7942, however, or on March 30, 1995, the

President entered into an FTAA with WMCP covering 99,387 hectares of land in

South Cotabato, Sultan Kudarat, Davao del Sur and North Cotabato.

On August 15, 1995, then DENR Secretary Victor O. Ramos issued DENR

Administrative Order (DAO) No. 95-23, s. 1995, otherwise known as the

Implementing Rules and Regulations of R.A. No. 7942. This was later repealed by

DAO No. 96-40, s. 1996 which was adopted on December 20, 1996.

On January 10, 1997, counsels for petitioners sent a letter to the DENR Secretary

demanding that the DENR stop the implementation of R.A. No. 7942 and DAO No.

96-40, giving the DENR fifteen days from receipt to act thereon. The DENR,

however, has yet to respond or act on petitioners' letter.

Petitioners claim that the DENR Secretary acted without or in excess of jurisdiction.

They pray that the Court issue an order:

(a) Permanently enjoining respondents from acting on any application for Financial

or Technical Assistance Agreements;

(b) Declaring the Philippine Mining Act of 1995 or Republic Act No. 7942 as

unconstitutional and null and void;

(c) Declaring the Implementing Rules and Regulations of the Philippine Mining Act

contained in DENR Administrative Order No. 96-40 and all other similar

administrative issuances as unconstitutional and null and void; and(d) Cancelling the Financial and Technical Assistance Agreement issued to Western

Mining Philippines, Inc. as unconstitutional, illegal and null and void.

Issue :

Whether or not Republic Act No. 7942 is unconstitutional.


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Ruling :

The Court finds the following provisions of R.A. No. 7942 to be violative of Section 2,

Article XII of the Constitution and hereby declares unconstitutional and void:

(1) The proviso in Section 3 (aq), which defines "qualified person," to wit:

Provided, That a legally organized foreign-owned corporation shall be deemed aqualified person for purposes of granting an exploration permit, financial or

technical assistance agreement or mineral processing permit.

(2) Section 23, which specifies the rights and obligations of an exploration

permittee, insofar as said section applies to a financial or technical assistance

agreement,

(3) Section 33, which prescribes the eligibility of a contractor in a financial or

technical assistance agreement;

(4) Section 35, which enumerates the terms and conditions for every financial or

technical assistance agreement;

(5) Section 39, which allows the contractor in a financial and technical assistance

agreement to convert the same into a mineral production-sharing agreement;

(6) Section 56, which authorizes the issuance of a mineral processing permit to a

contractor in a financial and technical assistance agreement;

The following provisions of the same Act are likewise void as they are dependent on

the foregoing provisions and cannot stand on their own:

(1) Section 3 (g), which defines the term "contractor," insofar as it applies to a

financial or technical assistance agreement.

Section 34, which prescribes the maximum contract area in a financial or technical

assistance agreements;

Section 36, which allows negotiations for financial or technical assistance

agreements;

Section 37, which prescribes the procedure for filing and evaluation of financial ortechnical assistance agreement proposals;

Section 38, which limits the term of financial or technical assistance agreements;

Section 40, which allows the assignment or transfer of financial or technical

assistance agreements;


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Section 41, which allows the withdrawal of the contractor in an FTAA;

The second and third paragraphs of Section 81, which provide for the Government's

share in a financial and technical assistance agreement; and

Section 90, which provides for incentives to contractors in FTAAs insofar as it

applies to said contractors;

When the parts of the statute are so mutually dependent and connected as

conditions, considerations, inducements, or compensations for each other, as to

warrant a belief that the legislature intended them as a whole, and that if all could

not be carried into effect, the legislature would not pass the residue independently,

then, if some parts are unconstitutional, all the provisions which are thus

dependent, conditional, or connected, must fall with them.

WHEREFORE, the petition is GRANTED.

Isagani Cruz vs DENR

Land Titles and Deeds IPRA Law vis a vis Regalian Doctrine

Cruz, a noted constitutionalist, assailed the validity of the RA 8371 or the

Indigenous Peoples Rights Act on the ground that the law amount to an unlawful

deprivation of the States ownership over lands of the public domain as well as

minerals and other natural resources therein, in violation of the regalian doctrine

embodied in Section 2, Article XII of the Constitution. The IPRA law basically

enumerates the rights of the indigenous peoples over ancestral domains which may

include natural resources. Cruz et al contend that, by providing for an all-

encompassing definition of ancestral domains and ancestral lands which might

even include private lands found within said areas, Sections 3(a) and 3(b) of said

law violate the rights of private landowners.

ISSUE: Whether or not the IPRA law is unconstitutional.


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HELD: The SC deliberated upon the matter. After deliberation they voted and

reached a 7-7 vote. They deliberated again and the same result transpired. Since

there was no majority vote, Cruzs petition was dismissed and the IPRA law was

sustained. Hence, ancestral domains may include public domain somehow against

the regalian doctrine

MULLER VS MULLER

Petitioner Elena Buenaventura Muller and respondent Helmut Muller were married

in Hamburg, Germany onSeptember 22, 1989. The couple resided in Germany at a

house owned by respondents parents but decided tomove and reside permanently

in the Philippines in 1992. By this time, respondent had inherited the house

inGermany from his parents which he sold and used the proceeds for the purchase

of a parcel of land in Antipolo,

Rizal at the cost of P528,000.00 and the construction of a house amounting to

P2,300,000.00. The Antipoloproperty was registered in the name of petitioner under

Transfer Certificate of Title No. 219438 5 of the Register of Deeds of Marikina,

Metro Manila.Due to incompatibilities and respondents alleged womanizing, drinkin

g, and maltreatment, the spouseseventually separated. On September 26, 1994,

respondent filed a petition 6 for separation of properties beforethe Regional Trial

Court of Quezon City.On August 12, 1996, the trial court rendered a decision which

terminated the regime of absolute community of property between the petitioner

and respondent. It also decreed the separation of properties between them

andordered the equal partition of personal properties located within the country,

excluding those acquired bygratuitous title during the marriage. With regard to

the Antipolo property, the court held that it was acquired using paraphernal funds of

the respondent. However, it ruled that respondent cannot recover his funds because

theproperty was purchased in violation of Section 7, Article XII of

the Constitution.The Court of Appeals rendered the assailed decision modifying the

trial courts Decision. As regards the house,the Court of Appeals ruled that there is

nothing in the Constitution which prohibits respondent from acquiring

thesame.Respondent claims that he is not praying for transfer of ownership of the

Antipolo property but merelyreimbursement; that the funds paid by him for the said

property were in consideration of his marriage topetitioner; that the funds weregiven to petitioner in trust; and that equity demands that respondent should

bereimbursed of his personal funds.

ISSUE: WON respondent is entitled to reimbursement of the funds used for the

acquisition of the Antipoloproperty.


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HELD: in the instant case, respondent cannot seek reimbursement on the ground of

equity where it is clear thathe willingly and knowingly bought the property despite

the constitutional prohibition.Further, the distinction made between transfer of

ownership as opposed to recovery of funds is a futile exerciseon respondents part.

To allow reimbursement would in effect permit respondent to enjoy the fruits of a

propertywhich he is not allowed to own. Thus, it is likewise proscribed by law. Asexpressly held in Cheesman v.Intermediate Appellate Court: 16Finally, the

fundamental law prohibits the sale to aliens of residential land. Section 14, Article

XIV of the 1973Constitution ordains that, "Save in cases of hereditary succession,

no private land shall be transferred or conveyed except to individuals, corporations,

or associations qualified to acquire or hold lands of the

publicdomain." Petitioner Thomas Cheesman was, of course, charged with

knowledge of this prohibition. Thus,assuming that it was his intention that the lot in

question be purchased by him and his wife, he acquired no rightwhatever over the

property by virtue of that purchase; and in attempting to acquire a right or interest

in land,vicariously and clandestinely, he knowingly violated the Constitution; the

sale as to him was null and void. In anyevent, he had and has no capacity or

personality to question the subsequent sale of the same property by hiswife on the

theory that in so doing he is merely exercising the prerogative of a husband in

respect of conjugalproperty. To sustain such a theory would permit indirect

controversion of the constitutional prohibition. If theproperty were to be declared

conjugal, this would accord to the alien husband a not insubstantial interest

andright over land, as he would then have a decisive vote as to its transfer or

disposition. This is a right that theConstitution does not permit him to have.As

already observed, the finding that his wife had used her own money to purchase the

property cannot, and willnot, at this stage of the proceedings be reviewed and

overturned. But even if it were a fact that said wife hadused conjugal funds to makethe acquisition, the considerations just set out to militate, on high

constitutionalgrounds, against his recovering and holding the property so acquired,

or any part thereof. And whether in suchan event, he may recover from his wife any

share of the money used for the purchase or charge her

withunauthorized disposition or expenditure of conjugal funds is not now

inquired into; that would be, in thepremises, a purely academic exercise. (Emphasis

added)WHEREFORE, in view of the foregoing, the instant petition is GRANTED. The

Decision dated February 26, 2001of the Court of Appeals in CA-G.R. CV No. 59321

ordering petitioner Elena Buenaventura Muller to reimburse

respondent Helmut Muller the amount of P528,000 for the acquisition of the land

and the amount of P2,300,000for the construction of the house in Antipolo City,

and the Resolution dated August 13, 2001 denyingreconsideration thereof, are

REVERSED and SET ASIDE. The August 12, 1996 Decision of the Regional TrialCourt

of Quezon City, Branch 86 in Civil Case No. Q-94-21862 terminating the regime of


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absolute communitybetween the petitioner and respondent, decreeing a separation

of property between them and ordering thepartition of the personal properties

located in the Philippines equally, is REINSTATED

Case Digest: Chavez v. National Housing Authority

Posted: August 4, 2010 in Case Digests

Tags: case, constitution, digest, land, law, nha, Philippines, territory 2

G.R. No. 164527 15 August 2007

Ponente: VELASCO, JR., J.

FACTS:

On August 5, 2004, former Solicitor General Francisco Chavez, filed an instant

petition raising constitutional issues on the JVA entered by National Housing

Authority and R-II Builders, Inc.

On March 1, 1988, then-President Cory Aquino issued Memorandum order No. (MO)

161 approving and directing implementation of the Comprehensive and Integrated

Metropolitan Manila Waste Management Plan. During this time, Smokey Mountain,

a wasteland in Tondo, Manila, are being made residence of many Filipinos living in asubhuman state.

As presented in MO 161, NHA prepared feasibility studies to turn the dumpsite into

low-cost housing project, thus, Smokey Mountain Development and Reclamation

Project (SMDRP), came into place. RA 6957 (Build-Operate-Transfer Law) was

passed on July 1990 declaring the importance of private sectors as contractors in

government projects. Thereafter, Aquino proclaimed MO 415 applying RA 6957 to

SMDRP, among others. The same MO also established EXECOM and TECHCOM in

the execution and evaluation of the plan, respectively, to be assisted by the Public

Estates Authority (PEA).

Notices of public bidding to become NHAs venture partner for SMDRP were

published in newspapers in 1992, from which R-II Builders, Inc. (RBI) won the

bidding process. Then-President Ramos authorized NHA to enter into a Joint

Venture Agreement with RBI.


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Under the JVA, the project involves the clearing of Smokey Mountain for eventual

development into a low cost housing complex and industrial/commercial site. RBI is

expected to fully finance the development of Smokey Mountain and reclaim 40

hectares of the land at the Manila Bay Area. The latter together with the

commercial area to be built on Smokey Mountain will be owned by RBI as enabling

components. If the project is revoked or terminated by the Government through nofault of RBI or by mutual agreement, the Government shall compensate RBI for its

actual expenses incurred in the Project plus a reasonable rate of return not

exceeding that stated in the feasibility study and in the contract as of the date of

such revocation, cancellation, or termination on a schedule to be agreed upon by

both parties.

To summarize, the SMDRP shall consist of Phase I and Phase II. Phase I of the

project involves clearing, levelling-off the dumpsite, and construction of temporary

housing units for the current residents on the cleared and levelled site. Phase II

involves the construction of a fenced incineration area for the on-site disposal of the

garbage at the dumpsite.

Due to the recommendations done by the DENR after evaluations done, the JVA was

amended and restated (now ARJVA) to accommodate the design changes and

additional work to be done to successfully implement the project. The original

3,500 units of temporary housing were decreased to 2,992. The reclaimed land as

enabling component was increased from 40 hectares to 79 hectares, which was

supported by the issuance of Proclamation No. 465 by President Ramos. The

revision also provided for the 119-hectare land as an enabling component for Phase

II of the project.

Subsequently, the Clean Air Act was passed by the legislature which made theestablishment of an incinerator illegal, making the off-site dumpsite at Smokey

Mountain necessary. On August 1, 1998, the project was suspended, to be later

reconstituted by President Estrada in MO No. 33.

On August 27, 2003, the NHA and RBI executed a Memorandum of Agreement

whereby both parties agreed to terminate the JVA and subsequent agreements.

During this time, NHA reported that 34 temporary housing structures and 21

permanent housing structures had been turned over by RBI.

ISSUES:


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Whether respondents NHA and RBI have been granted the power and authority to

reclaim lands of the public domain as this power is vested exclusively in PEA as

claimed by petitioner

Whether respondents NHA and RBI were given the power and authority by DENR to

reclaim foreshore and submerged lands

Whether respondent RBI can acquire reclaimed foreshore and submerged lands

considered as alienable and outside the commerce of man

Whether respondent RBI can acquire reclaimed lands when there was no

declaration that said lands are no longer needed for public use

Whether there is a law authorizing sale of reclaimed lands

Whether the transfer of reclaimed lands to RBI was done by public bidding

Whether RBI, being a private corporation, is barred by the Constitution to acquirelands of public domain

Whether respondents can be compelled to disclose all information related to the

SMDRP

Whether the operative fact doctrine applies to the instant position

HELD:

Executive Order 525 reads that the PEA shall be primarily responsible forintegrating, directing, and coordinating all reclamation projects for and on behalf of

the National Government. This does not mean that it shall be responsible for all.

The requisites for a valid and legal reclamation project are approval by the

President (which were provided for by MOs), favourable recommendation of PEA

(which were seen as a part of its recommendations to the EXECOM), and

undertaken either by PEA or entity under contract of PEA or by the National

Government Agency (NHA is a government agency whose authority to reclaim lands

under consultation with PEA is derived under PD 727 and RA 7279).

Notwithstanding the need for DENR permission, the DENR is deemed to have

granted the authority to reclaim in the Smokey Mountain Project for the DENR is oneof the members of the EXECOM which provides reviews for the project. ECCs and

Special Patent Orders were given by the DENR which are exercises of its power of

supervision over the project. Furthermore, it was the President via the

abovementioned MOs that originally authorized the reclamation. It must be noted

that the reclamation of lands of public domain is reposed first in the Philippine

President.


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The reclaimed lands were classified alienable and disposable via MO 415 issued by

President Aquino and Proclamation Nos. 39 and 465 by President Ramos.

Despite not having an explicit declaration, the lands have been deemed to be no

longer needed for public use as stated in Proclamation No. 39 that these are to be

disposed to qualified beneficiaries. Furthermore, these lands have already beennecessarily reclassified as alienable and disposable lands under the BOT law.

Letter I of Sec. 6 of PD 757 clearly states that the NHA can acquire property rights

and interests and encumber or otherwise dispose of them as it may deem

appropriate.

There is no doubt that respondent NHA conducted a public bidding of the right to

become its joint venture partner in the Smokey Mountain Project. It was noted that

notices were published in national newspapers. The bidding proper was done by

the Bids and Awards Committee on May 18, 1992.

RA 6957 as amended by RA 7718 explicitly states that a contractor can be paid aportion as percentage of the reclaimed land subject to the constitutional

requirement that only Filipino citizens or corporation with at least 60% Filipino

equity can acquire the same. In addition, when the lands were transferred to the

NHA, these were considered Patrimonial lands of the state, by which it has the

power to sell the same to any qualified person.

This relief must be granted. It is the right of the Filipino people to information on

matters of public concerned as stated in Article II, Sec. 28, and Article III, Sec. 7 of

the 1987 Constitution.

When the petitioner filed the case, the JVA had already been terminated by virtue ofMOA between RBI and NHA. The properties and rights in question after the passage

of around 10 years from the start of the projects implementation cannot be

disturbed or questioned. The petitioner, being the Solicitor General at the time

SMDRP was formulated, had ample opportunity to question the said project, but did

not do so. The moment to challenge has passed.

Manila Prince Hotel vs GSIS

Supremacy of the Constitution Filipino First Policy National Patrimony Qualified Filipinos

Pursuant to the privatization program of the government, GSIS decided to sell 30-

51% of the Manila Hotel Corporation. Two bidders participated, MPH and Malaysian

Firm Renong Berhad. MPHs bid was at P41.58/per share while RBs bid was at


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P44.00/share. RB was the highest bidder hence it was logically considered as the

winning bidder but is yet to be declared so. Pending declaration, MPH matches RBs

bid and invoked the Filipino First policy enshrined under par. 2, Sec. 10, Art. 12 of

the 1987 Constitution**, but GSIS refused to accept. In turn MPH filed a TRO to

avoid the perfection/consummation of the sale to RB.

RB then assailed the TRO issued in favor of MPH arguing among others that:

Par. 2, Sec. 10, Art. 12 of the 1987 Constitution needs an implementing law because

it is merely a statement of principle and policy (not self-executing);

Even if said passage is self-executing, Manila Hotel does not fall under national

patrimony.

ISSUE: Whether or not RB should be admitted as the highest bidder and hence be

proclaimed as the legit buyer of shares.

HELD: No. MPH should be awarded the sale pursuant to Art 12 of the 1987 Const.This is in light of the Filipino First Policy.

Par. 2, Sec. 10, Art. 12 of the 1987 Constitution is self executing. The Constitution is

the fundamental, paramount and supreme law of the nation, it is deemed written in

every statute and contract.

Manila Hotel falls under national patrimony. Patrimony in its plain and ordinary

meaning pertains to heritage. When the Constitution speaks of national patrimony,

it refers not only to the natural resources of the Philippines, as the Constitution

could have very well used the term natural resources, but also to the cultural

heritage of the Filipinos. It also refers to our intelligence in arts, sciences andletters. Therefore, we should develop not only our lands, forests, mines and other

natural resources but also the mental ability or faculty of our people. Note that, for

more than 8 decades (9 now) Manila Hotel has bore mute witness to the triumphs

and failures, loves and frustrations of the Filipinos; its existence is impressed with

public interest; its own historicity associated with our struggle for sovereignty,

independence and nationhood.

Herein resolved as well is the term Qualified Filipinos which not only pertains to

individuals but to corporations as well and other juridical entities/personalities. The

term qualified Filipinos simply means that preference shall be given to those

citizens who can make a viable contribution to the common good, because ofcredible competence and efficiency. It certainly does NOT mandate the pampering

and preferential treatment to Filipino citizens or organizations that are incompetent

or inefficient, since such an indiscriminate preference would be counter productive

and inimical to the common good.


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In the granting of economic rights, privileges, and concessions, when a choice has

to be made between a qualified foreigner and a qualified Filipino, the latter shall

be chosen over the former.

**Section 10. The Congress shall, upon recommendation of the economic and

planning agency, when the national interest dictates, reserve to citizens of the

Philippines or to corporations or associations at least sixty per centum of whose

capital is owned by such citizens, or such higher percentage as Congress may

prescribe, certain areas of investments. The Congress shall enact measures that will

encourage the formation and operation of enterprises whose capital is wholly owned

by Filipinos.

In the grant of rights, privileges, and concessions covering the national economy

and patrimony, the State shall give preference to qualified Filipinos.

The State shall regulate and exercise authority over foreign investments within its

national jurisdiction and in accordance with its national goals and priorities

Francisco Tatad et al vs Secretary of Energy

Equal Protection OilDeregulation Law

Considering that oil is not endemic to this country, historyshows that the

government has always been finding ways to alleviate the oil industry. The

government created laws accommodate these innovations in the oil industry. One

such law is the Downstream Oil Deregulation Act of 1996 or RA 8180. This law

allows that any person or entity may import or purchase any quantity of crude oil

and petroleum products from a foreign or domestic source, lease or own and

operate refineries and other downstream oil facilities and market such crude oil or

use the same for his own requirement, subject only to monitoring by the

Department of Energy. Tatad assails the constitutionality of the law. He claims,among others, that the imposition of different tariff rates on imported crude oil and

imported refined petroleum products violates the equal protection clause. Tatad

contends that the 3%-7% tariff differential unduly favors the three existing oil

refineries and discriminates against prospective investors in the downstream oil

industry who do not have their own refineries and will have to source refined


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petroleum products from abroad.3% is to be taxed on unrefined crude products and

7% on refined crude products.

ISSUE: Whether or not RA 8180 is constitutional.

HELD:The SC declared the unconstitutionality of RA 8180 because it

violated Sec 19 ofArt 12 of the Constitution. It violated thatprovision because it

only strengthens oligopoly which is contrary to free competition. It cannot be denied

that our downstream oil industry is operated and controlled by an oligopoly, a

foreign oligopoly at that. Petron, Shell and Caltex stand as the only major league

players in the oil market. All other players belong to the lilliputian league. As the

dominant players, Petron, Shell and Caltex boast of existing refineries of various

capacities. The tariff differential of 4% therefore works to their immense benefit.

Yet, this is only one edge of the tariff differential. The other edge cuts and cuts deep

in the heart of their competitors. It erects a high barrier to the entry of new players.

New players that intend to equalize the market power of Petron, Shell and Caltex by

building refineries of their own will have to spend billions of pesos. Those who willnot build refineries but compete with them will suffer the huge disadvantage of

increasing their product cost by 4%. They will be competing on an uneven field. The

argument that the 4% tariff differential is desirable because it will induce

prospective players to invest in refineries puts the cart before the horse. The first

need is to attract new players and they cannot be attracted by burdening them with

heavy disincentives. Without new players belonging to the league of Petron, Shell

and Caltex, competition in our downstream oil industry is an idle dream.

RA 8180 is unconstitutional on the ground inter alia that it discriminated against the

new players insofar as it placed them at a competitive disadvantage vis--vis the

established oil companies by requiring them to meet certain conditions alreadybeing observed by the latter.

J.G. Summit Holdings vs. CA

JG SUMMIT HOLDINGS, INC., vs. COURT OF APPEALS, COMMITTEE ON

PRIVATIZATION, ASSET PRIVATIZATION TRUST and PHILYARDS HOLDINGS G.R. No.

124293. November 20, 2000

FACTS:National Investment and Development Corporation (NIDC) and Kawasaki Heavy

Industries entered into a Joint Venture Agreement in a shipyard business named

PHILSECO, with a shareholding of 60-40 respectively. NIDCs interest was later

transferred to the National Government.

Pursuant to President Aquinos Proclamation No.5, which established the Committee

on Privatization (COP) and Asset Privatization Trust (APT), and allowed for the


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disposition of the governments non-performing assets, the latter allowed Kawasaki

Heavy Industries to choose a company to which it has stockholdings, to top the

winning bid of JG Summit Holdings over PHILSECO. JG Summit protested alleging

that such act would effectively increase Kawasakis interest in PHILSECOa

shipyard is a public utility--and thus violative of the Constitution.

ISSUE:

Whether or not respondents act is valid.

HELD:

No.

A shipyard such as PHILSECO being a public utility as provided by law, the following

provision of the Article XII of the Constitution applies:

Sec. 11. No franchise, certificate, or any other form of authorization for the

operation of a public utility shall be granted except to citizens of the Philippines or

to corporations or associations organized under the laws of the Philippines at least

sixty per centum of whose capital is owned by such citizens, nor shall such

franchise, certificate, or authorization be exclusive in character or for a longer

period than fifty years. Neither shall any such franchise or right be granted except

under the condition that it shall be subject to amendment, alteration, or repeal by

the Congress when the common good so requires. The State shall encourage equity

participation in public utilities by the general public. The participation of foreign

investors in the governing body of any public utility enterprise shall be limited to

their proportionate share in its capital, and all the executive and managing officers

of such corporation or association shall be citizens of the Philippines.

x x x

Notably, paragraph 1.4 of the JVA accorded the parties the right of first refusal

under the same terms. This phrase implies that when either party exercises the

right of first refusal under paragraph 1.4, they can only do so to the extent allowed

them by paragraphs 1.2 and 1.3 of the JVA or under the proportion of 60%-40% of

the shares of stock. Thus, should the NIDC opt to sell its shares of stock to a third

party, Kawasaki could only exercise its right of first refusal to the extent that its

total shares of stock would not exceed 40% of the entire shares of stock of SNS or

PHILSECO. The NIDC, on the other hand, may purchase even beyond 60% of the

total shares. As a government corporation and necessarily a 100% Filipino-ownedcorporation, there is nothing to prevent its purchase of stocks even beyond 60% of

the capitalization as the Constitution clearly limits only foreign capitalization.

Wilson P. Gamboa v. Finance Secretary Margarito Teves, et al., G.R. No. 176579,

June 28, 2011


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D E C I S I O N

CARPIO, J.:

I. THE FACTS

This is a petition to nullify the sale of shares of stock of Philippine

Telecommunications Investment Corporation (PTIC) by the government of the

Republic of the Philippines, acting through the Inter-Agency Privatization Council

(IPC), to Metro Pacific Assets Holdings, Inc. (MPAH), an affiliate of First Pacific

Company Limited (First Pacific), a Hong Kong-based investment management and

holding company and a shareholder of the Philippine Long Distance TelephoneCompany (PLDT).

The petitioner questioned the sale on the ground that it also involved an indirect

sale of 12 million shares (or about 6.3 percent of the outstanding common shares)

of PLDT owned by PTIC to First Pacific. With the this sale, First Pacifics common

shareholdings in PLDT increased from 30.7 percent to 37 percent, thereby

increasing the total common shareholdings of foreigners in PLDT to about

81.47%. This, according to the petitioner, violates Section 11, Article XII of the 1987

Philippine Constitution which limits foreign ownership of the capital of a public utilityto not more than 40%, thus:

Section 11. No franchise, certificate, or any other form of authorization for

the operation of a public utility shall be granted except to citizens of the

Philippines or to corporations or associations organized under the laws of

the Philippines, at least sixty per centum of whose capital is owned by

such citizens; nor shall such franchise, certificate, or authorization be exclusive in

character or for a longer period than fifty years. Neither shall any such franchise or

right be granted except under the condition that it shall be subject to amendment,

alteration, or repeal by the Congress when the common good so requires. The State

shall encourage equity participation in public utilities by the general public. The

participation of foreign investors in the governing body of any public utility

enterprise shall be limited to their proportionate share in its capital, and all the

executive and managing officers of such corporation or association must be citizens

of the Philippines. (Emphasis supplied)


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II. THE ISSUE

Does the term capital in Section 11, Article XII of the Constitution refer to the totalcommon shares only, or to the total outstanding capital stock (combined total of

common and non-voting preferred shares) of PLDT, a public utility?

III. THE RULING

[The Court partly granted the petition and held that the term capital in Section

11, Article XII of the Constitution refers only to shares of stock entitled to vote in the

election of directors of a public utility, i.e., to the total common shares in PLDT.]

Considering that common shares have voting rights which translate to control, as

opposed to preferred shares which usually have no voting rights, the term capital

in Section 11, Article XII of the Constitution refers only to common shares.

However, if the preferred shares also have the right to vote in the election of

directors, then the term capital shall include such preferred shares because the

right to participate in the control or management of the corporation is exercised

through the right to vote in the election of directors. In short, the term capital

in Section 11, Article XII of the Constitution refers only to shares of stock

that can vote in the election of directors.

To construe broadly the term capital as the total outstanding capital stock,

including both common and non-voting preferred shares, grossly contravenes the

intent and letter of the Constitution that the State shall develop a self-reliant and

independent national economy effectively controlled by Filipinos. A broad definition

unjustifiably disregards who owns the all-important voting stock, which necessarily

equates to control of the public utility.

Holders of PLDT preferred shares are explicitly denied of the right to vote in the

election of directors. PLDTs Articles of Incorporation expressly state that the

holders of Serial Preferred Stock shall not be entitled to vote at any

meeting of the stockholders for the election of directors or for any other

purpose or otherwise participate in any action taken by the corporation or its


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stockholders, or to receive notice of any meeting of stockholders. On the other

hand, holders of common shares are granted the exclusive right to vote in the

election of directors. PLDTs Articles of Incorporation state that each holder of

Common Capital Stock shall have one vote in respect of each share of such stock

held by him on all matters voted upon by the stockholders, and the holders of

Common Capital Stock shall have the exclusive right to vote for theelection of directors and for all other purposes.

It must be stressed, and respondents do not dispute, that foreigners hold a majority

of the common shares of PLDT. In fact, based on PLDTs 2010 General Information

Sheet (GIS), which is a document required to be submitted annually to the

Securities and Exchange Commission, foreigners hold 120,046,690 common shares

of PLDT whereas Filipinos hold only 66,750,622 common shares. In other words,

foreigners hold 64.27% of the total number of PLDTs common shares, while

Filipinos hold only 35.73%. Since holding a majority of the common shares equatesto control, it is clear that foreigners exercise control over PLDT. Such amount of

control unmistakably exceeds the allowable 40 percent limit on foreign ownership of

public utilities expressly mandated in Section 11, Article XII of the Constitution.

As shown in PLDTs 2010 GIS, as submitted to the SEC, the par value of PLDT

common shares is P5.00 per share, whereas the par value of preferred shares

is P10.00 per share. In other words, preferred shares have twice the par value of

common shares but cannot elect directors and have only 1/70 of the dividends of

common shares. Moreover, 99.44% of the preferred shares are owned by Filipinoswhile foreigners own only a minuscule 0.56% of the preferred shares. Worse,

preferred shares constitute 77.85% of the authorized capital stock of PLDT while

common shares constitute only 22.15%. This undeniably shows that beneficial

interest in PLDT is not with the non-voting preferred shares but with the common

shares, blatantly violating the constitutional requirement of 60 percent Filipino

control and Filipino beneficial ownership in a public utility.

In short, Filipinos hold less than 60 percent of the voting stock, and earn less than

60 percent of the dividends, of PLDT. This directly contravenes the expresscommand in Section 11, Article XII of the Constitution that [n]o franchise,

certificate, or any other form of authorization for the operation of a public utility

shall be granted except to x x x corporations x x x organized under the laws of the

Philippines, at least sixty per centum of whose capital is owned by such citizens x x

x.


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To repeat, (1) foreigners own 64.27% of the common shares of PLDT, which class of

shares exercises the sole right to vote in the election of directors, and thus exercise

control over PLDT; (2) Filipinos own only 35.73% of PLDTs common shares,

constituting a minority of the voting stock, and thus do not exercise control over

PLDT; (3) preferred shares, 99.44% owned by Filipinos, have no voting rights; (4)

preferred shares earn only 1/70 of the dividends that common shares earn; (5)preferred shares have twice the par value of common shares; and (6) preferred

shares constitute 77.85% of the authorized capital stock of PLDT and common

shares only 22.15%. This kind of ownership and control of a public utility is a

mockery of the Constitution.

[Thus, the Respondent Chairperson of the Securities and Exchange Commission

was DIRECTED by the Court to apply the foregoing definition of the term capital

in determining the extent of allowable foreign ownership in respondent Philippine

Long Distance Telephone Company, and if there is a violation of Section 11, ArticleXII of the Constitution, to impose the appropriate sanctions under the law.]

Liban v. Gordon

G.R. 175352

January 18, 2011

FACTS

Richard J. Gordon (respondent) filed for a Motion for Clarification and/or for

Reconsideration on the promulgated Decision by the Court on July 15, 2009. The

case brought about by the petitioners was regarding to Gordons forfeiture of hisseat in the Senate when he accepted the Chairmanship in the Philippine National

Red Cross (PNRC). The court ruled that it was not the case, as PNRC is not a

government-owned and controlled corporation for the purpose of prohibition in Sect.

13, Art. VI of the 1987 Constitution. The Court, however, further declared void the

PNRC Charter (as in R.A. 95) insofar as it creates the PNRC as a private

corporation and consequently ruled that the PNRC should incorporate under the

Corporation Code and register with the Securities and Exchange Commission if it

wants to be a private corporation.

Respondent argues that the validity of R.A. 95 was not an issue in theaforementioned case; the petitioners did not raise its constitutionality. As the court

decided, the petitioners did not have standing to file the instant petition. Hence, the

pronouncement of the Court on the validity of R.A. No. 95 should be considered

obiter.

ISSUE


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Are the provisions of R.A. No. 95 valid and constitutional?

HELD

Yes. Richard J. Gordons Motion for Clarification and/or Reconsideration and movant-

intervenor PNRCs Motion for Partial Reconsideration of the Decision in G.R. No.175352 dated July 15, 2009 were granted. The constitutionality of R.A. No. 95, as

amended, the charter of the Philippine National Red Cross, was not raised by the

parties as an issue and should not have been passed upon by the Court. The

structure of the PNRC, being neither strictly private nor public in nature, R.A. 95

remains valid and constitutional in its entirety.

Petition for Leave to Resume Practice of Law, Benjamin Dacanay 540 SCRA 424

FACTS: Petitioner was admitted to the Philippine bar in March 1960. He practiced

law until he migrated to Canada in December 1998 to seek medical attention for his

ailments. He subsequently applied for Canadian citizenship to avail of Canadas free

medical aid program. His application was approved and he became a Canadian

citizen in May 2004.

In July 2006, pursuant to Republic Act (RA) 9225 (Citizenship Retention and Re-

Acquisition Act of 2003), petitioner reacquired his Philippine citizenship. On that

day, he took his oath of allegiance as a Filipino citizen before the Philippine

Consulate General in Toronto, Canada. Thereafter, he returned to the Philippines

and now intends to resume his law practice.

ISSUE: Whether petitioner may still resume practice?

RULING: Section 2, Rule 138 of the Rules of Court provides an applicant for

admission to the bar be a citizen of the Philippines, at least twenty-one years of

age, of good moral character and a resident of the Philippines.5 He must also

produce before this Court satisfactory evidence of good moral character and that no


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charges against him, involving moral turpitude, have been filed or are pending in

any court in the Philippines.

Since Filipino citizenship is a requirement for admission to the bar, loss thereof

terminates membership in the Philippine bar and, consequently, the privilege to

engage in the practice of law. In other words, the loss of Filipino citizenship ipso jureterminates the privilege to practice law in the Philippines. The practice of law is a

privilege denied to foreigners.

The exception is when Filipino citizenship is lost by reason of naturalization as a

citizen of another country but subsequently reacquired pursuant to RA 9225. This is

because all Philippine citizens who become citizens of another country shall be

deemed not to have lost their Philippine citizenship under the conditions of [RA

9225]. Therefore, a Filipino lawyer who becomes a citizen of another country is

deemed never to have lost his Philippine citizenship if he reacquires it in accordance

with RA 9225.

Before he can can resume his law practice, he must first secure from this Court the

authority to do so, conditioned on:

the updating and payment of of IBP membership dues;

the payment of professional tax;

the completion of at least 36 credit hours of mandatory continuing legal

education; this is specially significant to refresh the applicant/petitioners

knowledge of Philippine laws and update him of legal developments and

the retaking of the lawyers oath.


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DEFENSOR-SANTIAGO vs. COMELEC(G.R. No. 127325 - March 19,

1997)Facts:

Private respondent Atty. Jesus Delfin, president of Peoples Initiative for Reforms,Mo

dernization and Action (PIRMA), filed with COMELEC a petition to amend the

constitution to lift the term limits of elective officials, through Peoples Initiative. He

based this petition on Article XVII,Sec. 2 of the 1987 Constitution, which provides for

the right of the people to exercise the power to directly propose amendments to the

Constitution. Subsequently the COMELEC issued an order directing the publication

of the petition and of the notice of hearing and thereafter set the case for hearing.

At the hearing, Senator Roco, the IBP, Demokrasya-Ipagtanggol ang Konstitusyon,

PublicInterest Law Center, and Laban ng Demokratikong Pilipino appeared as

intervenors-oppositors. Senator Roco filed a motion to dismiss the Delfin petition on

the ground that one which is cognizableby the COMELEC. The petitioners herein

Senator Santiago, Alexander Padilla, and Isabel Ongpinfiled this civil action forprohibition under Rule 65 of the Rules of Court against COMELEC and theDelfin

petition rising the several arguments, such as the following: (1) The constitutional

provision onpeoples initiative to amend the constitution can only be implemented

by law to be passed byCongress. No such law has been passed; (2) The peoples

initiative is limited to amendments to theConstitution, not to revision thereof. Lifting

of the term limits constitutes a revision, therefore it isoutside the power of

peoples initiative. The Supreme Court granted the Motions for Intervention.

Issues:

(1) Whether or not Sec. 2, Art. XVII of the 1987 Constitution is a self-executingprovision.(2) Whether or not COMELEC Resolution No. 2300 regarding the conduct

of initiative onamendments to the Constitution is valid, considering the absence in

the law of specific provisions onthe conduct of such initiative.(3) Whether the lifting

of term limits of elective officials would constitute a revision or anamendment of the

Constitution.

Held:

Sec. 2, Art XVII of the Constitution is not self executory, thus, without implementingl

egislation the same cannot operate. Although the Constitution has recognized or

granted the right,the people cannot exercise it if Congress does not provide for itsimplementation.The portion of COMELEC Resolution No. 2300 which prescribes rules

and regulations on theconduct of initiative on amendments to the Constitution, is

void. It has been an established rule

thatwhat has been delegated, cannot be delegated (potestas delegata non delegari

potest). Thedelegation of the power to the COMELEC being invalid, the latter cannot

validly promulgate rulesand regulations to implement the exercise of the right to

peoples initiative.The lifting of the term limits was held to be that of a revision, as it


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would affect other provisions of the Constitution such as the synchronization of

elections, the constitutional guaranteeof equal access to opportunities for public

service, and prohibiting political dynasties. A revisioncannot be done by initiative.

However, considering the Courts decision in the above Issue, the issueof whether

or not the petition is a revision or amendment has become academic

ARTURO M. TOLENTINO vs. COMMISSION ON ELECTIONS

G.R. No. L-34150 October 16, 1971

FACTS:

The case is a petition for prohibition to restrain respondent Commission on Elections

"from undertaking to hold a plebiscite on November 8, 1971," at which the

proposed constitutional amendment "reducing the voting age" in Section 1 of Article

V of the Constitution of the Philippines to eighteen years "shall be, submitted" forratification by the people pursuant to Organic Resolution No. 1 of the Constitutional

Convention of 1971, and the subsequent implementing resolutions, by declaring

said resolutions to be without the force and effect of law for being violative of the

Constitution of the Philippines. The Constitutional Convention of 1971 came into

being by virtue of two resolutions of the Congress of the Philippines approved in its

capacity as a constituent assembly convened for the purpose of calling a

convention to propose amendments to the Constitution namely, Resolutions 2 and 4

of the joint sessions of Congress held on March 16, 1967 and June 17, 1969

respectively. The delegates to the said Convention were all elected under and by

virtue of said resolutions and the implementing legislation thereof, Republic Act

6132.

ISSUE:

Is it within the powers of the Constitutional Convention of 1971 to order the holding

of a plebiscite for the ratification of the proposed amendment/s.

HELD: The Court holds that all amendments to be proposed must be submitted to

the people in a single "election" or plebiscite. We hold that the plebiscite being

called for the purpose of submitting the same for ratification of the people on

November 8, 1971 is not authorized by Section 1 of Article XV of the Constitution,

hence all acts of the Convention and the respondent Comelec in that direction arenull and void. lt says distinctly that either Congress sitting as a constituent

assembly or a convention called for the purpose "may propose amendments to this

Constitution,". The same provision also as definitely provides that

"such amendments shall be valid as part of this Constitution when approved by a

majority of the votes cast at an election at which the amendments are submitted to

the people for their ratification," thus leaving no room for doubt as to how many


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"elections" or plebiscites may be held to ratify any amendment or amendments

proposed by the same constituent assembly of Congress or convention, and the

provision unequivocably says "an election" which means only one.

The petition herein is granted. Organic Resolution No. 1 of the Constitutional

Convention of 1971 and the implementing acts and resolutions of the Convention,insofar as they provide for the holding of a plebiscite on November 8, 1971, as well

as the resolution of the respondent Comelec complying therewith (RR Resolution

No. 695) are hereby declared null and void. The respondents Comelec, Disbursing

Officer, Chief Accountant and Auditor of the Constitutional Convention are hereby

enjoined from taking any action in compliance with the said organic resolution. In

view of the peculiar circumstances of this case, the Court declares this decision

immediately executory. No costs

Lambino & Aumentado vs COMELEC

Amendmentvs Revision

Lambino was able to gather the signatures of 6,327,952 individuals for

an initiativepetition to amend the 1987 Constitution. That said number of votes

comprises at least 12 per centum of all registered voters with each legislative

district at least represented by at least 3 per centum of its registered voters. This

has been verified by local COMELEC registrars as well. The proposed amendment to

the constitution seeks to modify Secs 1-7 of Art VI and Sec 1-4 of Art VII and by

adding Art XVIII entitled Transitory Provisions.These proposed changes will shift

the president bicameral-presidential system to a Unicameral-Parliamentary form of

government. The COMELEC, on 31 Aug 2006, denied the petition of the Lambino

group due to the lack of an enabling law governing initiative petitions to amend theConstitution this is in pursuant to the ruling in Santiago vs COMELEC. Lambino et

al contended that the decision in the aforementioned case is only binding to the

parties within that case.

ISSUE: Whether or not the petition for initiative met the requirements of Sec 2

ArtXVII of the 1987 Constitution.

HELD:The proponents of the initiative secure the signatures from the people. The

proponents secure the signatures in their private capacity and not as public

officials. The proponents are not disinterested parties who can impartially explain

the advantages and disadvantages of the proposed amendments to the people.The proponents present favorably their proposal to the people and do not present

the arguments against their proposal. The proponents, or their supporters, often

pay those who gather the signatures. Thus, there is no presumption that the

proponents observed the constitutional requirements in gathering the signatures.

The proponents bear the burden of proving that they complied with the

constitutional requirements in gathering the signatures that the petition

contained, or incorporated by attachment, the full text of the proposed


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amendments. The proponents failed to prove that all the signatories to the

proposed amendments were able to read and understand what the petition

contains. Petitioners merely handed out the sheet where people can sign but they

did not attach thereto the full text of the proposed amendments.

Lambino et al are also actually proposing a revision of the constitution and not amere amendment. This is also in violation of the logrolling rule wherein a proposed

amendment should only contain one issue. The proposed amendment/s by

petitioners even includes a transitory provision which would enable the would-be

parliament to enact more rules.

There is no need to revisit the Santiago case since the issue at hand can be decided

upon other facts. The rule is, the Court avoids questions of constitutionality so long

as there are other means to resolve an issue at bar.

***NOTE: On November 20, 2006 in a petition for reconsideration submitted by theLambino Group 10 (ten) Justices ofthe Supreme Court voted that Republic Act 6735

is adequate.

****RA 6735: An Act Providing for a System of Initiative and Referendum and

Appropriating Funds Therefor

Documents

National Economy, Patrimony and Ammendment Cases