Case Digest: De Guzman, Jr. vs. COMELEC, G.R. No. 129118 . July 19, 2000 .

Equal Protection of the Laws | Constitutional Law


Facts:

(1) Republic Act No. 8189 (The Voter’s Registration Act of 1996) was enacted on June 10, 1996 and approved by President Fidel V. Ramos on June 11, 1996. Section 44 thereof provides:

SEC. 44. Reassignment of Election Officers.— No Election Officershall hold office in a particular city or municipality for more than four (4) years. Any election officer who, either at the time of the approval of this Act or subsequent thereto, has served for at least four (4) years in a particular city or municipality shall automatically be reassigned by the Commission to a new station outside the original congressional district.

(2) By virtue of the aforequoted provision of law, the Commission on Elections (COMELEC) promulgated Resolution Nos. 97-0002 and 97-0610 for the implementation thereof. Thereafter, the COMELEC issued several directives reassigning the petitioners, who are either City or Municipal Election Officers, to different stations.

(3) Aggrieved by the issuance of the aforesaid directives and resolutions, petitioners assail the validity of Section 44 of RA 8189.


Issue:

WoN Section 44 of RA 8189 violates the 'Equal Protection Clause' enshrined in the constitution because it singles out the City and Municipal Election Officers of the COMELEC as prohibited from holding office in the same city or municipality for more than four (4) years.

Held:

The Court is not persuaded by petitioners’ arguments. The “equal protection clause” of the 1987 Constitution permits a valid classification under the following conditions:

  1. The classification must rest on substantial distinctions;
  2. The classification must be germane to the purposeof the law;
  3. The classification must not be limited to existing conditions only; and
  4. The classification must apply equally to all members of the same class.
After a careful study, the ineluctable conclusion is that the classification under Section 44 of RA 8189 satisfies the aforestated requirements.

The singling out of election officers in order to “ensure the impartiality of election officials by preventing themfrom developing familiarity with the people of their place ofassignment” does not violate the equal protection clause of the Constitution.

It may be true that all the other officers of COMELEC referred to by petitioners are exposed to the same evils sought to be addressed by the statute. However, in this case, it can be discerned that the legislature thought the noble purpose of the law would be sufficiently served by breaking an important link in the chain of corruption than by breaking up each and every link thereof.

Election officers are the highest officials or authorized representatives of the COMELEC in a city or municipality. It is safe to say that without the complicity of such officials, large scale anomalies in the registration of voters can hardly be carried out.

Moreover, to require the COMELEC to reassign allemployees (connected with the registration of voters) who have served at least four years in a given city or municipality would entail a lot of administrative burden on the part of the COMELEC.


Ratio:

Underinclusiveness is not an argument against a valid classification.

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