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Republic of the Philippines


G.R. No. 108399 July 31, 1997
RAFAEL M. ALUNAN III, in i! "#$#"i%y #! S&"'&%#'y o( %& )&$#'%*&n% o( In%&'io' #n+
Lo"#l Go,&'n*&n% -)ILG., %& /OAR) OF ELECTION SUPER0ISORS "o*$o!&+ o(
ROA, GUILLERMINA RUSTIA, in &' "#$#"i%y #! )i'&"%o' o( %& /#'#n4#y /u'&#u,
Ci%y T'&#!u'&' A%%y. ANTONIO ACE/E)O, /u+4&% O((i"&' EUFEMIA )OMINGUE1, #ll
o( %& Ci%y Go,&'n*&n% o( M#nil#, petitioners,
6ONORA/LE 7ILFRE)O ). RE2ES, P'&!i+in4 Ju+4& o( %& R&4ion#l T'i#l Cou'%,
/'#n" 38, M&%'o M#nil#, respondents.

MEN)O1A, J.:
This is a petition for review on certiorari of the decision dated Januar !", !""# of the
Re$ional Trial Court of Manila %Branch #&',
nullifin$ an order of the (epart)ent of *nterior and
+ocal ,overn)ent %(*+,', which in effect cancelled the $eneral elections for the -an$$unian$ .abataan
%-.' slated on (ece)ber /, !""0 in the Cit of Manila, on the $round that the elections previousl held on
Ma 0&, !""1 served the purpose of the first elections for the -. under the +ocal ,overn)ent Code of
!""! %R.A. No. 2!&1'.
-ection /0# of the Code provides for a -. in ever baran$a, to be co)posed of a
chair)an, seven %2' )e)bers, a secretar, and a treasurer. -ection 3#0%a' provides that
the first elections for the -. shall be held thirt %#1' das after the ne4t local elections. The
Code too5 effect on Januar !, !""0.
The first local elections under the Code were held on Ma !!, !""0. Accordin$l, on Au$ust
02, !""0, the Co))ission on Elections issued Resolution No. 0/"", providin$ $uidelines for
the holdin$ of the $eneral elections for the -. on -epte)ber #1, !""0 The $uidelines
placed the -. elections under the direct control and supervision of the (*+,, with the
technical assistance of the C6ME+EC.
After two postpone)ents, the elections were finall
scheduled on (ece)ber /, !""0.
Accordin$l, re$istration in the si4 districts of Manila was conducted. A total of !30,#&#
oun$sters, a$ed !3 to 0! ears old, re$istered, !3,2/" of the) filin$ certificates of
candidacies. The Cit Council passed the necessar appropriations for the elections.
6n -epte)ber !7, !""0, however, the (*+,, throu$h then -ecretar Rafael M. Alunan ***,
issued a letter8resolution 9e4e)ption9 the Cit of Manila fro) holdin$ elections for the -. on
the $round that the elections previousl held on Ma 0&, !""1 were to be considered the
first under the newl8enacted +ocal ,overn)ent Code. The (*+, acted on a letter of
Joshue R. -antia$o, actin$ president of the .B Cit :ederation of Manila and a )e)ber of
Cit Council of Manila, which called attention to the fact that in the Cit of Manila elections
for the .abataan$ Baran$a %the precursor of the -an$$unian$ .abataan' had previousl
been held on Ma 0&, !""1. *n its resolution, the (*+, stated;
<A= close e4a)ination of . . . RA 2!&1 would readil reveal the intention of the
le$islature to e4e)pt fro) the forthco)in$ -an$$unian$ .abataan elections those
5abataan$ baran$a chapters which )a have conducted their elections within the
period of Januar !, !"77 and Januar !, !""0 under BP ##2. Manifestl the ter) of
office of those elected .B officials have been correspondin$l e4tended to coincide
with the ter) of office of those who )a be elected under RA 2!&1.
6n Nove)ber 02, !""0 private respondents, clai)in$ to represent the 0/,111 )e)bers of
the .atipunan n$ .abataan, filed a petition for certiorari and )anda)us in the RTC of
Manila to set aside the resolution of the (*+,. The ar$ued that petitioner -ecretar of
*nterior and +ocal ,overn)ent had no power to a)end the resolutions of the C6ME+EC
callin$ for $eneral elections for -.s and that the (*+, resolution in >uestion denied the)
the e>ual protection of the laws.
6n Nove)ber 02, !""0, the trial court, throu$h E4ecutive Jud$e, now C6ME+EC
Chair)an, Bernardo P. Pardo, issued an in?unction, orderin$ petitioners 9to desist fro)
i)ple)entin$ the order of the respondent -ecretar dated -epte)ber !7, !""0, . . . until
further orders of the Court.9 6n the sa)e da, he ordered petitioners 9to perfor) the
specified pre8election activities in order to i)ple)ent Resolution No. 0/"" dated Au$ust 02,
!""0 of the Co))ission on Elections providin$ for the holdin$ of a $eneral election of the
-an$$unian$ .abataan on (ece)ber /, !""0 si)ultaneousl in ever baran$a throu$hout
the countr.9
The case was subse>uentl reraffled to Branch #& of the sa)e court. 6n Januar !", !""#,
the new ?ud$e, @on. Ailfredo (. Rees, rendered a decision, holdin$ that %!' the (*+, had
no power to 9e4e)pt9 the Cit of Manila fro) holdin$ -. elections on (ece)ber /, !""0
because under Art. *B, C, C0%!' of the Constitution the power to enforce and ad)inister 9all
laws and re$ulations relative to the conduct of an election, plebiscite, initiative, referendu),
and recall9 is vested solel in the C6ME+ECD %0' the C6ME+EC had alread in effect
deter)ined that there had been no previous elections for .B b callin$ for $eneral elections
for -. officers in ever baran$a without e4ceptionD and %#' the 9e4e)ption9 of the Cit of
Manila was violative of the e>ual protection clause of the Constitution because, accordin$ to
the (*+,Es records, in 3,111 baran$as .B elections were held between Januar !, !"77
and Januar !, !""0 but onl in the Cit of Manila, where there were 7"2 baran$as, was
there no elections held on (ece)ber /, !""0.
Petitioners sou$ht this review on certiorari. The insist that the Cit of Manila, havin$
alread conducted elections for the .B on Ma 0&, !""1, was e4e)pted fro) holdin$
elections on (ece)ber /, !""0. *n support of their contention, the cite C3#0%d' of the +ocal
,overn)ent Code of !""!, which provides that;
All seats reserved for the pederason n$ )$a san$$unian$ 5abataan in the different
san$$unian$ shall be dee)ed vacant until such ti)e that the san$$unian$ 5abataan
chair)en shall have been elected and the respective pederason presidents have
been selected; Provided, That, elections for the kabataang barangay conducted
under Batas Pambansa Blg. 337 at any time between January 1, 19 and January
1, 199! shall be considered as the first elections "rovided for in this #ode. The term
of office of the kabataang barangay officials elected within the said "eriod shall be
e$tended corres"ondingly to coincide with the term of office of those elected under
this #ode. %e)phasis added'
The )aintain that the -ecretar of the (*+, has authorit to deter)ine whether the Cit of
Manila ca)e within the e4ception clause of C3#0%d' so as to be e4e)pt fro) holdin$ the
elections on (ece)ber /, !""0.
The preli)inar >uestion is whether the holdin$ of the second elections on Ma !#,
rendered this case )oot and acade)ic. There are two >uestions raised in this case. The first is
whether the -ecretar of *nterior and +ocal ,overn)ent can 9e4e)pt9 a local $overn)ent unit fro)
holdin$ elections for -. officers on (ece)ber /, !""0 and the second is whether the C6ME+EC can
provide that 9the (epart)ent of *nterior and +ocal ,overn)ent shall have direct control and supervision
over the election of san$$unian$ 5abataan with the technical assistance b the Co))ission on
Ae hold that this case is not )oot and that it is in fact necessar to decide the issues raised
b the parties. :or one thin$, doubt )a be cast on the validit of the acts of those elected
in the Ma 0&, !""1 .B elections in Manila because this Court en?oined the enforce)ent of
the decision of the trial court and these officers continued in office until Ma !#, !""&. :or
another, this case co)es within the rule that courts will decide a >uestion otherwise )oot
and acade)ic if it is 9capable of repetition, et evadin$ review.9
:or the >uestion whether the
C6ME+EC can validl vest in the (*+, the control and supervision of -. elections is li5el to arise in
connection with ever -. election and et the >uestion )a not be decided before the date of such
*n the %outhern Pacific Terminal case, where the rule was first articulated, appellants were
ordered b the *nterstate Co))erce Co))ission to cease and desist fro) $rantin$ a
shipper what the *CC perceived to be preferences and advanta$es with respect to wharfa$e
char$es. The cease and desist order was for a period of about two ears, fro) -epte)ber
!, !"17 %subse>uentl e4tended to Nove)ber !3', but the F.-. -upre)e Court had not
been able to hand down its decision b the ti)e the cease and desist order e4pired. The
case was decided onl on :ebruar 01, !"!!, )ore than two ears after the order had
e4pired. @ence, it was contended that the case had thereb beco)e )oot and the appeal
should be dis)issed. *n re?ectin$ this contention, the Court held;
The >uestion involved in the orders of the *nterstate Co))erce Co))ission are
usuall continuin$ %as are )anifestl those in the case at bar', and these
considerations ou$ht not to be, as the )i$ht be, defeated, b short8ter) orders,
capable of repetition, et evadin$ review, and at one ti)e the $overn)ent, and at
another ti)e the carriers, have their ri$hts deter)ined b the Co))ission without a
chance of redress.
*n &oe v. 'ade,
petitioner, a pre$nant wo)an, brou$ht suit in !"21 challen$in$ anti8abortion statutes
of Te4as and ,eor$ia on the $round that she had a constitutional ri$ht to ter)inate her pre$nanc at least
within the first tri)ester. The case was not decided until !"2# when she was no lon$er pre$nant. But the
F.-. -upre)e Court refused to dis)iss the case as )oot. *t was e4plained; 9<A=hen, as here, pre$nanc
is a si$nificant fact the liti$ation, the nor)al 0&&8da hu)an $estation period is so short that the
pre$nanc will co)e to ter) before the usual appellate process is co)plete. *f that ter)ination )a5es a
case )oot, pre$nanc liti$ation seldo) will survive. 6ur laws should not be that ri$id. Pre$nanc provides
a classic ?ustification for a conclusion of non)ootness. *t trul could be Ecapable of repetition, et evadin$
Ae thus reach the )erits of the >uestions raised in this case. The first >uestion is whether
then (*+, -ecretar Rafael M. Alunan *** had authorit to deter)ine whether under C3#0%d'
of the +ocal ,overn)ent Code, the Cit of Manila was re>uired to hold its first elections for
-.. As alread stated, petitioners sustain the affir)ative side of the proposition. 6n the
other hand, respondents ar$ue that this is a power which Art. *B, C, C0%!' of the Constitution
vests in the C6ME+EC. Respondents further ar$ue that, b )andatin$ that elections for the
-. be held on (ece)ber /, !""0 9in ever baran$a,9 the C6ME+EC in effect deter)ined
that there had been no elections for the .B previousl held in the Cit of Manila.
Ae find the petition to be )eritorious.
(irst. As alread stated, b C/ of Resolution No. 0/"", the C6ME+EC placed the -.
elections under the direct control and supervision of the (*+,. Contrar to respondentsE
contention, this did not contravene Art. *B, C, C0%!' of the Constitution which provides that
the C6ME+EC shall have the power to 9enforce and ad)inister all laws and re$ulations
relative to the conduct of an election, plebiscite, initiative, referendu), and recall.9 Elections
for -. officers are not sub?ect to the supervision of the C6ME+EC in the sa)e wa that, as
we have recentl held, contests involvin$ elections of -. officials do not fall within the
?urisdiction of the C6ME+EC. *n )ercado v. Board of *lection %u"ervisors,
it was contended
C6ME+EC Resolution No. 0/"" is null and void because; %a' it prescribes a
separate set of rules for the election of the -. Chair)an different fro) and
inconsistent with that set forth in the 6)nibus Election Code, thereb contravenin$
-ection 0, Article ! of the said Code which e4plicitl provides that 9it shall $overn all
elections of public officers9, and, %b' it constitutes a total, absolute, and co)plete
abdication b the C6ME+EC of its constitutionall and statutoril )andated dut to
enforce and ad)inister all election laws as provided for in -ection 0%!', Article *B8C
of the ConstitutionD -ection 30, Article G*** of the 6)nibus Election CodeD and
-ection 0, Chapter !, -ubtitle C, Title !, Boo5 G of the !"72 Ad)inistrative Code.
Re?ectin$ this contention, this Court, throu$h Justice (avide, held;
-ection 030 of the 6)nibus Election Code and that portion of para$raph %0', -ection
0, Article *B8C of the Constitution on the C6ME+ECEs e4clusive appellate ?urisdiction
over contest involvin$ elective baran$a officials refer to the elective baran$a
officials under the pertinent laws in force at the ti)e the 6)nibus Election Code was
enacted and upon the ratification of the Constitution. That law was B.P. Bl$. ##2,
otherwise 5nown as the +ocal ,overn)ent Code, and the elective baran$a officials
referred to were the punon$ baran$a and the si4 san$$unian$ baan )e)bers.
The were to be elected b those >ualified to e4ercise the ri$ht of suffra$e. The are
also the sa)e officers referred to b the provisions of the 6)nibus Election Code of
the Philippines on election of baran$a officials. Metropolitan and )unicipal trial
courts had e4clusive ori$inal ?urisdiction over contests relatin$ to their election. The
decisions of these courts were appealable to the Re$ional Trial Courts.
444 444 444
*n the li$ht of the fore$oin$, it is indisputable that contests involvin$ elections of -.
%for)erl .B' officials do not fall within -ection 030 of the 6)nibus Election Code
and para$raph 0, -ection 0, Article *B8C of the Constitution and that no law in effect
prior to the ratification of the Constitution had )ade the -. chair)an an elective
baran$a officials. @is bein$ an e48officio )e)ber of the san$$unian$ baran$a
does not )a5e hi) one for the law specificall provides who are its elective
)e)bers, viH., the punon$ baran$a and the seven re$ular san$$unian$ baran$a
)e)bers who are elected at lar$e b those who are >ualified to e4ercise the ri$ht of
suffra$e under Article G of the Constitution and who are dul re$istered voters of the
The choice of the (*+, for the tas5 in >uestion was appropriate and was in line with the
le$islative polic evident in several statutes. Thus, P.(. No. &7/ %April !3, !"23', in creatin$
.abataan$ Baran$as in ever baran$a throu$hout the countr, provided in C& that the
9-ecretar of +ocal ,overn)ent and Co))unit (evelop)ent shall pro)ul$ate such rules
and re$ulations as )a be dee)ed necessar to effectivel i)ple)ent the provisions of this
(ecree.9 A$ain, in !"73 Procla)ation No. 0/0! of the President of the Philippines, in callin$
for the $eneral elections of the .abataan$ Baran$a on Jul !#8!/, !"73, tas5ed the then
Ministr of +ocal ,overn)ent, the Ministr of Education, Culture and -ports, and the
Co))ission on Elections to assist the .abataan$ Baran$a in the conduct of the elections.
6n the other hand, in a Me)orandu) Circular dated March 2, !"77, President CoraHon C.
A>uino directed the -ecretar of +ocal ,overn)ent to issue the necessar rules and
re$ulations for effectin$ the representation of the .abataan$ Baran$a, a)on$ other
sectors, in the le$islative bodies of the local $overn)ent units.
The role of the C6ME+EC in the !""0 elections for -. officers was b no )eans
inconse>uential. (*+, supervision was to be e4ercised within the fra)ewor5 of detailed and
co)prehensive rules e)bodied in Resolution No. 0/"" of the C6ME+EC. Ahat was left to
the (*+, to perfor) was the enforce)ent of the rules.
%econd. *t is contended that, in its resolution in >uestion, the C6ME+EC did not na)e the
baran$as which, because the had conducted 5abataan$ baran$a elections between
Januar !, !"77 and Januar !, !""0, were not included in the -. elections to be held on
(ece)ber /, !""0. That these baran$as were precisel to be deter)ined b the (*+, is,
however, fairl inferable fro) the authorit $iven to the (*+, to supervise the conduct of the
elections. -ince C3#0%d' provided for 5abataan$ baran$a officials whose ter) of office was
e4tended beond !""0, the authorit to supervise the conduct of elections in that ear )ust
necessaril be dee)ed to include the authorit to deter)ine which 5abataan$ baran$a
would not be included in the !""0 elections.
The authorit $ranted was nothin$ )ore than the ascertain)ent of a fact, na)el, whether
between Januar !, !"77 and Januar !, !""0 elections had been held in a $iven
5abataan$ baran$a. *f elections had been conducted, then no new elections had to be held
on (ece)ber /, !""0 since b virtue of C3#0%d' the ter) of office of the 5abataan$
baran$a officials so elected was 9e4tended correspondin$l to coincide with the ter) of
office of those elected under <the +ocal ,overn)ent Code of !""!=.9 *n doin$ this, the
-ecretar of *nterior and +ocal ,overn)ent was to act )erel as the a$ent of the le$islative
depart)ent, to deter)ine and declare the event upon which its e4pressed will was to ta5e
There was no undue dele$ation of le$islative power but onl of the discretion as to the e4ecution
of a law. That this is constitutionall per)issible is the teachin$ of our cases.
Third. Respondents clai), however, that the Ma 0&, !""1 .B elections in Manila were void
because %a' the were called at the instance of then Maor ,e)iliano C. +opeH who did not
have authorit to do so and %b' it was not held under C6ME+EC supervision.
The !""1 elections for the .abataan$ Baran$a were called b then Manila Maor
,e)iliano C. +opeH, Jr., who in his E4ecutive 6rder No. 0! dated April 03, !""1 stated;
A@EREA-, the .abataan$ Baran$a as an or$aniHation provided for under Batas
Pa)bansa Bilan$ ##2, has been practicall dor)ant since the advent of the present
national ad)inistrationD
A@EREA-, there is an ur$ent need to involve the outh in the affairs and
underta5in$ of the $overn)ent to ensure the participation of all sectors of our
population in the tas5 of nation buildin$D
A@EREA-, the last elections for the .abataan$ Baran$a officers were held in
Nove)ber !"73 et, which is over their three ears ter) of officeD
A@EREA-, )ost of the present crop of .B officers are wa past the a$e li)it
provided for under the lawD
444 444 444
The elections were actuall held on Ma 0&, !""1 in the 7"2 baran$as of Manila. +ater, on
June #1, !""1, .B Cit :ederation elections were conducted.
*t was precisel to foreclose an >uestion re$ardin$ the validit of .B elections held in the
after)ath of the E(-A revolution and upon the effectivit of the new +ocal ,overn)ent
Code that the e4ception clause of C3#0%d' was inserted. The proceedin$s of the Bica)eral
Conference Co))ittee which drafted the Code show the followin$;
C@A*RMAN (E PE(R6; *sa8cite na lan$ 5o ano ion$ title o chapter o section, haI
@6N. +*NA; . . .
Pa$e /#&, lines !# to !/ delete within ei$hteen )onths prior to (ece)ber #!, !""1,
and in lieu thereof, insert fro) !"77 up to the effectivit of the Code. The rationale. . .
C@A*RMAN (E PE(R6; @ow should it be readJ
@6N. +*NA; *t will read as follows; 9Provided however, that the +ocal ,overn)ent
Fnits which have conducted elections for the .abataan$ Baran$a as provided for,
in Batas Pa)bansa Bilan$ ##2, up to the effectivit. . . .9
C@A*RMAN (E PE(R6; -o, an deletion fro) the word 9within,9 ha, up to. . . .
@6N. +*NA; Re)ove the words, the phrase, 9within ei$hteen )onths prior to
(ece)ber #!, !""1, and insert fro) !"77 up to the effectivit of this Code.9
C@A*RMAN (E PE(R6; :ro)J
@6N. +*NA; :ro) !"77 up to the effectivit of this Code. .asi )eron nan$ )$a
election, eh, na $inawa, eh.There are five thousand barangays, based on the record
of the +,-., out of forty thousand, imaging that, na nag/conduct na ng election nila
based on the 0B #onstitution and By/-aws, and they1re sitting already, now if we do
not recogni2e that, mag3ka4karoon sila ng 5uestion.
C@A*RMAN (E PE(R6; Accepted, Mr. Chair)an.
-ection C3#0%d' )a thus be dee)ed to be a curative law. Curative laws, which in essence
are retrospective in effect, are enacted to validate acts done which otherwise would be
invalid under e4istin$ laws, b considerin$ the) as havin$ co)plied with the e4istin$ laws.
-uch laws are reco$niHed in this ?urisdiction.
(ourth. *t is finall contended that the e4e)ption of the baran$as of the Cit of Manila fro)
the re>uire)ent to hold elections for -. officers on (ece)ber /, !""0 would den the outh
voters in those baran$as of the e>ual protection of laws. Respondent clai) that onl in
baran$as in the Cit of Manila, which then nu)bered 7"2, were elections for -. not held in
!""0 on the $round that between Januar !, !"77 and Januar !, !""0 there had alread
been -. elections held, when, accordin$ to petitionersE own evidence, durin$ that period,
-. elections had actuall been conducted in 3,111 baran$as.
Ahether this clai) is true cannot be ascertained fro) the records of this case. Merel
showin$ that there were 3,111 baran$as which si)ilarl held .B elections between
Januar !, !"77 and Januar !, !""0 does not prove that despite that fact these sa)e
baran$as were per)itted to hold elections on (ece)ber /, !""0. :or one thin$, accordin$
to the )anila Bulletin issue of Nove)ber !7, !""0 %p. "', 3&7 baran$as in the Province of
Bulacan did not have -. elections on (ece)ber /, !""0 either, because the alread had
elections between Januar !, !"77 and Januar !, !""0. :or another, even assu)in$ that
onl baran$as in Manila were not per)itted to hold -. elections on (ece)ber /, !""0
while the rest of the 3,111 baran$as were allowed even if .B elections had alread been
held there before, this fact does not $ive the outh voters in the 7"2 Manila baran$as
$round for co)plaint because what the other baran$as did was contrar to law. There is no
discri)ination here.
*n Peo"le v. 6era
this Court struc5 down the Probation +aw because it per)itted une>ual application
of its benefits b )a5in$ its applicabilit depend on the decision of provincial $overn)ents to appropriate
or not to appropriate funds for the salaries of probation officers, with the result that those not disposed to
allow the benefits of probations to be en?oed b their inhabitants could si)pl o)it to provide for the
salaries of probation officers. The difference between that case and the one at bar lies in the fact that
what outh voters in the other baran$as )i$ht have been allowed was not a ri$ht which was denied to
outh voters in Manila. *f those baran$as were not entitled to have -. elections on (ece)ber /, !""0
but nevertheless were allowed to have such elections, that fact did not )ean those in Manila should
si)ilarl have been allowed to conduct elections on (ece)ber /, !""0 because the fact was that the
alread had their own, ?ust two ears before on Ma 0&, !""1. RespondentsE e>ual protection ar$u)ent
violates the dictu) that one wron$ does not )a5e another wron$ ri$ht.
A@ERE:6RE, the decision of the Re$ional Trial Court of Manila, Branch #& is REGER-E(
and the case filed a$ainst petitioner b private respondents is (*-M*--E(.
-6 6R(ERE(.
Padilla, &egalado, +avide, Jr7, &omero, Bellosillo, )elo, Puno, 6itug, 0a"unan, (rancisco,
8ermosisima, Jr7 and Panganiban, JJ7, concur7
9arvasa, #7J7 and Torres, Jr7, J7, are on leave7
! Per Jud$e Ailfredo (. Rees, &ollo, pp. 20871.
0 Resolution No. 0/"", CC0 and /.
# The second elections were held pursuant to R.A. No. 2717, approved on
-epte)ber 0, !""/ which provided that 9the re$ular elections for the
san$$unian$ 5abataan shall be held on the first Monda of Ma
!""&; Provided, further. That the succeedin$ re$ular elections for the
san$$unian$ 5abataan shall be held ever three %#' ears
thereafter; Provided, finally, that the national, special )etropolitan, provincial,
cit, and )unicipal federations of the san$$unian$ 5abataan shall conduct the
election of their respective officers thirt %#1' das after the Ma !""&
san$$unian$ 5abataan elections on dates to be scheduled b the
Co))ission on Elections.9
/ -outhern Pac. Ter)inal Co. v. *CC, 0!" F.-. /"7, 33 +.Ed. #!1 %!"!!';
Moore v. 6$ilvie, #"/ F.-. 7!/, 0# +.Ed.0d ! %!"&"' %challen$e to si$nature
re>uire)ent on no)inatin$ petitions, election had been held before the F.-.
-upre)e Court could decide case'D (unn v. Blu)stein, /13 F.-. ##1, #!
+.Ed.0d 02/ %!"20' %F.-. -upre)e Court decided )erits of a challen$e to
durational residenc re>uire)ent for votin$ even thou$h Blu)stein had in the
)eanti)e satisfied that re>uire)ent'.
3 ,d. at 3!3, 33 +.Ed. at #!&.
& /!1 F.-. !!#, #3 +.Ed.0d !/2 %!"2#'.
2 ,d. at !03, #3 +.Ed.0d at !&!.
7 0/# -CRA /00 %!""3'.
" ,d, at /0&.
!1 ,d, at /#/.
!! Pana)a Refinin$ Co. v. Ran, 0"# F.-. #77, 2" +.Ed. /&" %!"#3'.
!0 CruH v. Koun$ber$, 3& Phil. 0#/ %!"#!'; Edu v. Ericta, !/& Phil. /&"
!# Records of (eliberations of the Bica)eral Conference Co))ittee on
+ocal ,overn)ent, Ma #!, !""!, pp. /83 %e)phasis added'.
!/ Municipalit of -an Narciso, LueHon v. MendeH, -r., 0#" -CRA !! %!""/'.
!3 &3 Phil. 3& %!"#2'.