Villavicencio vs.

Lukban
G.R. No. L-14639
25 March 1919

FACTS: One hundred and seventy women of ill repute were isolated from society, and then at
night, without their consent and without any opportunity to consult with friends or to defend
their rights, were forcibly hustled on board steamers for transportation to regions unknown.
Despite the feeble attempt to prove that the women left voluntarily and gladly, that such was
not the case is shown by the mere fact that the presence of the police and the constabulary was
deemed necessary and that these officers of the law chose the shades of night to cloak their
secret and stealthy acts. Indeed, this is a fact impossible to refute and practically admitted by the
respondents.

ISSUE: WON Mayor Justo Lukban of Manila has the right to deport to Davao these women?

RULING: No, the Mayor has no authority to deport these women. The Philippines is a government
of law, hence, no official, no matter how high, is above the law. These women, despite their being
in a sense lepers of society, are nevertheless not chattles, but Philippine citizens protected by the
same constitutional guaranties as are other citizens. Lukban committed a grave abuse of
discretion by deporting the prostitutes to a new domicile against their will. There is no law
expressly authorizing his action. On the contrary, there is a law punishing public officials, not
expressly authorized by law or regulation, who compels any person to change his residence
Furthermore, the prostitutes are still, as citizens of the Philippines, entitled to the same rights,
as stipulated in the Bill of Rights, as every other citizen. Thei rchoice of profession should not be
a cause for discrimination. It may make some, like Lukban, quite uncomfortable but it does not
authorize anyone to compel said prostitutes to isolate themselves from the rest of the human
race. These women have been deprived of their liberty by being exiled to Davao without even
being given the opportunity to collect their belongings or, worse, without even consenting to
being transported to Mindanao.

The SC ruled that the forcible taking of these women from Manila by officials of that city, who
handed them over to other parties, who deposited them in a distant region, deprived these
women of freedom of locomotion just as effectively as if they had been imprisoned is a proper
subject of petition for the issuance of the writ of habeas corpus. The restraint of liberty which
began in Manila continued until the aggrieved parties were returned to Manila and released or
until they freely and truly waived this right. A prime specification of an application for a writ of
habeas corpus is restraint of liberty. The essential objects and purpose of the writ of habeas
corpus is to inquire into all manner of involuntary restraint as distinguished from voluntary, and
to relieve a person therefrom if such restraint is illegal. Any restraint which will preclude freedom
of action is sufficient.
 Kuroda vs. Jalandoni
G.R. No. L-2662
26 March 1949

FACTS: Shigenori Kuroda, formerly a Lieutenant-General of the Japanese Imperial Army and
Commanding General of the Japanese Imperial Forces in The Philippines during Second World
War. He was charged before a military commission convened by the Chief of Staff of the Armed
forces of the Philippines with having unlawfully disregarded and failed to discharge his duties as
such command, permitting them to commit brutal atrocities and other high crimes against
noncombatant civilians and prisoners of the Imperial Japanese Forces in violation of the laws and
customs of war”. The said military commission was empaneled under the authority of Executive
Order 68 of the President of the Philippines. Kuroda challenged the validity of Executive Order
68. His arguments, were as follows: (1) Executive Order 68 is illegal on the ground that it violates
not only the provisions of our constitutional law but also our local laws. (2) Military Commission
has no Jurisdiction to try him for acts committed in violation of the Hague Convention and the
Geneva Convention because the Philippines is not a signatory to the first and signed the second
only in 1947 and, therefore, he is charged with “crime” not based on law, national or
international;

ISSUE: WON EO 68 is unconstitutional and without basis on local or even international law?

RULING: No. Executive Order 68 has not violated the provision of our constitutional law. The
tribunal has jurisdiction to try Kuroda. This executive order is in accordance with Article 2 Sec 3,
of Constitution. It is in accordance with generally accepted principles of international law
including the Hague Convention and Geneva Convention, and other international jurisprudence
established by the UN, including the principle that all persons (military or civilian) guilty of plan,
preparing, waging a war of aggression and other offenses in violation of laws and customs of war.

The provision of Article 2 Sec 3 states that “The Philippines renounces war as an instrument of
national policy, adopts 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”. Every State is, by reason of its membership in the family of nations, bound by the
generally accepted principles of international law, which are considered to be automatically part
of its own laws. Hence, in accordance with the generally accepted principles of international law
of the present day, including the Hague Convention, the Geneva Convention and significant
precedents of international jurisprudence established by the United Nations, all those persons,
military of civilian, who have been guilty of planning, preparing or waging a war of aggression
and of the commission of crimes and offenses consequential and incidental thereto, in violation
of the laws and customs of war, of humanity and civilization, are held accountable therefor.

The SC ruled that the Philippines may not be a signatory to the 2 conventions at that time but the
rules and regulations of both are wholly based on the generally accepted principles of
international law.
 Agustin vs. Edu
G.R. No. L-49112
02 February 1979

FACTS: This case is a petition assailing the validity or the constitutionality of a Letter of Instruction
No. 229, issued by President Ferdinand E. Marcos, requiring all vehicle owners, users or drivers
to procure early warning devices to be installed a distance away from such vehicle when it stalls
or is disabled. In compliance with such letter of instruction, the Commissioner of the Land
Transportation Office issued Administrative Order No. 1 directing the compliance thereof. This
petition alleges that such letter of instruction and subsequent administrative order are unlawful
and unconstitutional as it violates the provisions on due process, equal protection of the law and
undue delegation of police power. Petitioner argued that it is oppressive, unreasonable,
arbitrary, confiscatory and contrary to the precepts of our compassionate New Society. The
respondents, on the other hand, assailed Letter of Instruction was a valid exercise of the police
power; that the implementing rules and regulations of respondent Land Transportation
Commissioner do not constitute unlawful delegation of legislative power and that the hazards
posed by such obstructions to traffic have been recognized by international bodies concerned
with traffic safety, the 1968 Vienna Convention on Road Signs and Signals of which Philippines
was a signatory and which was duly ratified and the United Nations Organization.

ISSUE: WON LoI No. 229 and AO No. 1 are unconstitutional?

RULING: No. The Supreme Court ruled that these were issued definitely in the exercise of police
power as such was established to promote public welfare and public safety. In fact, the letter of
instruction is based on the constitutional provision of adopting to the generally accepted
principles of international law as part of the law of the land. The letter of instruction mentions,
as its premise and basis, the resolutions of the 1968 Vienna Convention on Road Signs and Signals
and the discussions on traffic safety by the United Nations - that such letter was issued in
consideration of a growing number of road accidents due to stalled or parked vehicles on the
streets and highways. The SC emphasized that the said Vienna Convention, which was ratified by
the Philippine Government under P.D. No. 207, recommended the enactment of local legislation
for the installation of road safety signs and devices this is in line with the principle that the
Philippines adopts the generally accepted principles of international law as part of the law of the
land, and the 1968 Vienna Convention on Road Signs and Signals is impressed with such a
character. It is not for this country to repudiate a commitment to which it had pledged its word.
The concept of Pacta sunt servanda stands in the way of such an attitude, which is, moreover, at
war with the principle of international morality.
 Ichong vs. Hernandez
G.R. No. L-7995
31 March 1957

FACTS: Driven by aspirations for economic independence and national security, the Congress
enacted Act No. 1180 entitled “An Act to Regulate the Retail Business.” The main provisions of
the Act, among others, are: (1) Prohibition against persons, not citizens of the Philippines, and
against associations, among others, from engaging directly or indirectly in the retail trade; and
(2) Prohibition against the establishment or opening by aliens actually engaged in the retail
business of additional stores or branches of retail business. Lao H. Ichong, in his own behalf and
on behalf of other alien residents, corporations and partnerships adversely affected by the said
Act, brought an action to obtain a judicial declaration, and to enjoin the Secretary of Finance,
Jaime Hernandez, and all other persons acting under him, particularly city and municipal
treasurers, from enforcing its provisions. Petitioner attacked the constitutionality of the Act,
contending that it denies to alien residents the equal protection of the laws and deprives of their
liberty and property without due process of law and the Act violates international and treaty
obligations of the Republic of the Philippines.

ISSUE: WON Act No. 1180 is unconstitutional for being violative of an existing treaty?

RULING: No. Act No. 1180 is valid and may legally supersede a treaty or a generally accepted
principle. In this case, the Supreme Court saw no conflict between the raised generally accepted
principle and with RA 1180. The equal protection of the law clause “does not demand absolute
equality amongst residents; it merely requires that all persons shall be treated alike, under like
circumstances and conditions both as to privileges conferred and liabilities enforced” and, that
the equal protection clause “is not infringed by legislation which applies only to those persons
falling within a specified class, if it applies alike to all persons within such class, and reasonable
grounds exist for making a distinction between those who fall within such class and those who
do not.”

The SC further ruled that a generally accepted principle of international law, should be observed
by the Philippines in good faith. However, if a treaty would be in conflict with a statute then the
statute must be upheld because it is an exercise of the police power which, being inherent to the
State, could not be bargained away or surrendered through the medium of a treaty.

The SC concluded that the law does not violate international treaties and obligations. The United
Nations Charter imposes no strict or legal obligations regarding the rights and freedom of their
subjects, and the Declaration of Human Rights contains nothing more than a mere
recommendation, or a common standard of achievement for all peoples and all nations. The
Treaty of Amity between the Republic of the Philippines and the Republic of China of April 18,
1947 guarantees equality of treatment to the Chinese nationals “upon the same terms as the
nationals of any other country.” But the nationals of China are not discriminated against because
nationals of all other countries, except those of the United States, who are granted special rights
by the Constitution, are all Prohibited from engaging in the retail trade. But even supposing that
the law infringes upon the said treaty, the treaty is always subject to qualification or amendment
by a subsequent law, and the same may never curtail or restrict the scope of the police power of
the State.
 Gonzales vs. Hechanova
G.R. No. L-21897
22 October 1963

FACTS: Exec. Secretary Hechanova authorized the importation of foreign rice to be purchased
from private sources. Gonzales filed a petition opposing the said implementation because RA No.
3542 which allegedly repeals or amends RA No. 2207, prohibits the importation of rice and corn
by the Rice and Corn Administration or any other government agency. Respondents alleged that
the importation permitted in RA 2207 is to be authorized by the President of the Philippines, and
by or on behalf of the Government of the Philippines. They added that after enjoining the Rice
and Corn administration and any other government agency from importing rice and corn, Sec. 10
of RA 3542 indicates that only private parties may import rice under its provisions. They
contended that the government has already constitute valid executive agreements with Vietnam
and Burma, hence, the Court has no authority to invalidate the said executive agreement.

ISSUE: WON the international agreement may be invalidated by the Court?

RULING: Yes. The alleged consummation of the contracts with Vietnam and Burma does not
render this case academic. RA 2207, enjoins our government not from entering contracts for the
purchase of rice, but from entering rice, except under conditions prescribed in said act.

The Constitution provides that the Supreme Court may not be deprived of its jurisdiction to
review, revise, reverse, modify, or affirm on appeal, certiorari, or writ of error as the law or the
rules of court may provide, final judgments and decrees of inferior courts in all cases in which the
constitutionality or validity of any treaty, law, ordinance, or executive order, or regulation is in
question. In other words, according to the High Court, our Constitution authorizes the
nullification of a treaty, not only when it conflicts with the fundamental law, but also, when it
runs counter to an act of Congress. As ruled by the Court, although the President may, under the
American constitutional system, enter into executive agreements without previous legislative
authority, he may not, by executive agreement, enter into a transaction which is prohibited by
statutes enacted prior thereto. Under the Constitution, he may not defeat legislative enactments
that have acquired the status of laws, by indirectly repealing the same through an executive
agreement providing for the performance of the very act prohibited by said laws.

The SC clarified that a judicial declaration of illegality of the proposed importation would not
compel our government to default in the performance of such obligations as it may have
contracted with the sellers of rice in question because aside from the fact that said obligations
may be complied without importing the said commodity into the Philippines, the proposed
importation may still be legalized by complying with the provisions of the aforementioned law.
 Calalang vs. Williams
G.R. No. 47800
02 December 1940

FACTS: Pursuant to the power delegated to it by the Legislature, the Director of Public Works,
based on the recommendation of the National Traffic Commission, promulgated rules and
regulations pertaining to the closure of Rosario Street and Rizal Avenue from 7:30 am to 12 pm
and 1:30 pm to 5:30 pm and also along Rizal Avenue from 7 am to 11 pm to traffic of animal-
drawn vehicles for a year from the date of the opening of the Colgante Bridge to traffic. It was
subsequently passed and thereafter enforce by Manila Mayor and the acting chief of police.
Among others, the petitioner Calalang, concerned citizen, aver that the rules and regulations
complained of infringe upon constitutional precept on the promotion of social justice to insure
the well being and economic security of all people; and, that it constitutes unlawful interference
with legitimate business or trade and abridge the right to personal liberty and freedom of
locomotion.

ISSUE: WON the regulation and the law to which it is based infringe the promotion of social
justice?

RULING: No, the regulation still promotes social justice. In enacting the said law, the National
Assembly was prompted by considerations of public convenience and welfare. The SC quote the
basic definition of Social justice that it is neither communism, nor despotism, nor atomism, nor
anarchy, but the humanization of laws and the equalization of social and economic force by the
State so that justice in its rational and objectively secular conception may at least be
approximated. The promotion of the welfare of all the people, the adoption by the Government
of measures calculated to insure economic stability of all the competent elements of society,
through the maintenance of a proper economic and social equilibrium in the interrelations of the
members of the community, constitutionally, through the adoption of measures legally
justifiable, or extra-constitutionally, through the exercise of powers underlying the existence of
all governments on the time-honored principle of salus populi est suprema lex.

Social justice must be founded on the recognition of the necessity of interdependence among
divers and diverse units of a society and of the protection that should be equally and evenly
extended to all groups as a combined force in our social and economic life, consistent with the
fundamental and paramount objective of the state of promoting the health, comfort and quiet
of all persons, and of bringing about the greatest good to the greatest number.

The SC concluded that Commonwealth Act No. 548 was passed by the National Assembly in the
exercise of the paramount police power of the state. Said Act, by virtue of which the rules and
regulations complained of were promulgated, aims to promote safe transit upon and avoid
obstructions on national roads, in the interest and convenience of the public. In enacting said
law, therefore, the National Assembly was prompted by considerations of public convenience
and welfare. It was inspired by a desire to relieve congestion of traffic, which is, to say the least,
a menace to public safety. Public welfare, then, lies at the bottom of the enactment of said law,
and the state in order to promote the general welfare may interfere with personal liberty, with
property, and with business and occupations.
 Almeda vs. CA
G.R. No. L-43800
29 July 1977

FACTS: This is an agrarian case about a tenant’s right of redemption in sugar and coconut lands
and how should redemption be done. Herein Respondent Eulogio Gonzales is an agricultural
share tenant of a parcel of land situated in Tanauan, Batangas, and devoted to sugar cane and
coconuts. On September 30, 1968, the landowners sold the property to petitioners-spouses
Leonila Laurel Almeda and Venancio Almeda without notifying respondent-tenant in writing of
the sale. The document of sale was registered with the Register of Deeds of Tanauan, Batangas
on March 21, 1969. Respondent-tenant thus seeks the redemption of the land in a complaint
filed on March 27, 1971, pursuant to the provisions of Sections 11 and 12 of the Code of Agrarian
Reforms, with the Court of Agrarian Relations at Lipa City without the proper tender of payment
for the said redemption. However, on October 10, 1973, the Agrarian Court rendered judgment
authorizing, the respondent-tenant, Eulogio Gonzales, to redeem the tenanted land for
P24,000.00, the said amount to be deposited by him with the Clerk of Court within fifteen (15)
days from receipt of the decision. Petitioners-spouses appealed the case to the Court of Appeals,
which affirmed the decision of the Agrarian Court.

ISSUE: WON Respondent Gonzales has the right to redeem the property?

RULING: The SC ruled that while, yes, Respondent has the right to redeem the property,
Respondent, however, failed to redeem it within the period prescribed by law.

The SC said that under the new Constitution, property ownership is impressed with social
function. Property use must not only be for the benefit of the owner but of society as well. The
State, in the promotion of social justice, may regular the acquisition, ownership, use, enjoyment
and disposition of private property, and equitably diffuse property ownership and profits. One
governmental policy of recent date projects the emancipation of tenants from the bondage of
the soil and the transfer to them of the ownership of the land they till.

The SC clarified that prior to the enactment of RA 3844 or the Agricultural Land Reform Code no
right of preference in the sale of the land under cultivation was enjoyed by the tenant-farmer.
The absence of this right freely opened the way to the landlords to ease out their tenants from
the land by ostensible conveyance of said land to another tenant who, in turn, sues for the
ejectment of the first tenant on ground of personal cultivation. While many of these sales were
simulated, the SC said that the tenant is oftenly evicted from the land because of the formal
transfer of ownership in the land. Hence, the law was passed and impressed with the policy of
the State to establish owner-cultivatorship and the economic family-size farm as the basis of
Philippine agriculture; to achieve a dignified existence of the small farmers free from pernicious
institutional restraints and practices; to make the small farmers more independent, self-reliant
and responsible citizens, and a source of genuine strength in our democratic society and more
importantly, a new right was given by the law to the tenants-farmers, the right of pre-emption
and redemption.

However, in the present case, considering that the same law allows redemption, said redemption
must be done in accordance with the law and since respondent failed to comply with the
procedure of redemption such as the tender of payment within 180 days from notice, respondent
lost his right to redeem the same.
 LLDA vs. CA
G.R. No. 110120
16 March 1994

FACTS: The residents of Tala Estate, Barangay Camarin, Caloocan City raised a complaint with the
LLDA seeking to stop the operation of the City Government of Caloocan of an open garbage
dumpsite in Tala Estate, due to its harmful effects on the health of the residents and the pollution
of the surrounding water. LLDA discovered that the City Government of Caloocan has been
maintaining the open dumpsite at the Camarin Area without a requisite Environmental
Compliance Certificate from the Environmental Management Bureau of the DENR. They also
found the water to have been directly contaminated by the operation of the dumpsite. Hence,
LLDA issued a Cease and Desist Order against the City Government and other entities to
completely halt, stop and desist from dumping any form or kind of garbage and other waste
matter on the Camarin dumpsite. The City Government went to the Regional Trial Court of
Caloocan City to file an action for the declaration of nullity of the cease and desist order and
sought to be declared as the sole authority empowered to promote the health and safety and
enhance the right of the people in Caloocan City to a balanced ecology within its territorial
jurisdiction.

ISSUE: WON the LLDA has authority and power to issue an order which, in its nature and effect
was injunctive.

RULING: Yes, the LLDA has the authority to issue cease and desist order under the law. The SC
ruled that LLDA is mandated by law to manage the environment, preserve the quality of human
life and ecological systems and prevent undue ecological disturbances, deterioration and
pollution in the Laguna Lake area and surrounding provinces and cities, including Caloocan. The
SC went beyond when it ruled that even assuming that the authority to issue a “cease and desist
order” were not expressly conferred by law to LLDA, there is jurisprudence enough to the effect
that the rule granting such authority need not necessarily be express. While it is a fundamental
rule that an administrative agency has only such powers as are expressly granted to it by law, it
is likewise a settled rule that an administrative agency has also such powers as are necessarily
implied in the exercise of its express powers. In the exercise, therefore, of its express powers
under its charter as a regulatory and quasi-judicial body with respect to pollution cases in the
Laguna Lake region, the authority of the LLDA to issue a “cease and desist order” is, perforce,
implied. Otherwise, it may well be reduced to a “toothless” paper agency.

The SC concluded that the immediate response to the demands of “the necessities of protecting
vital public interests” gives vitality to the statement on ecology embodied in the Declaration of
Principles and State Policies or the 1987 Constitution, particularly Article II, Section 16. Hence, as
a constitutionally guaranteed right of every person, it carries the correlative duty of non-
impairment. This is but in consonance with the declared policy of the state “to protect and
promote the right to health of the people and instill health consciousness among them.” It is to
be borne in mind, according to the High Court, that the Philippines is party to the Universal
Declaration of Human Rights and the Alma Conference Declaration of 1978 which recognize
health as a fundamental human right.
 Basco vs. Pagcor
G.R. No. 91649
14 May 1991

FACTS: In 1977, the Philippine Amusements and Gaming Corporation (PAGCOR) was created by
Presidential Decree 1067-A. PD 1067-B meanwhile granted PAGCOR the power “to establish,
operate and maintain gambling casinos on land or water within the territorial jurisdiction of the
Philippines.” PAGCOR’s operation was a success hence in 1978, PD 1399 was passed which
expanded PAGCOR’s power. In 1983, PAGCOR’s charter was updated through PD 1869. PAGCOR’s
charter provides that PAGCOR shall regulate and centralize all games of chance authorized by
existing franchise or permitted by law. Section 1 of PD 1869. Atty. Humberto Basco and several
other lawyers assailed the validity of the law creating PAGCOR. They claim that PD 1869 is
unconstitutional because a) it violates the equal protection clause and b) it violates the local
autonomy clause of the constitution. Basco et al argued that PD 1869 violates the equal
protection clause because it legalizes PAGCOR-conducted gambling, while most other forms of
gambling are outlawed, together with prostitution, drug trafficking and other vices. Anent the
issue of local autonomy, Basco et al contend that P.D. 1869 forced cities like Manila to waive its
right to impose taxes and legal fees as far as PAGCOR is concerned a grave violation of the
principle of local autonomy.

ISSUE: WON the law violates the principle of local autonomy?

RULING: No. The SC clarified that while each local government unit shall have the power to create
its own source of revenue and to levy taxes, fees, and other charges subject to such guidelines
and limitation as the congress may provide, consistent with the basic policy on local autonomy
and that Such taxes, fees and charges shall accrue exclusively to the local government. A close
reading of the above provision does not violate local autonomy (particularly on taxing powers)
as it was clearly stated that the taxing power of LGUs are subject to such guidelines and limitation
as Congress may provide. Further, the City of Manila, being a mere Municipal corporation has no
inherent right to impose taxes. The Charter of the City of Manila is subject to control by Congress.

The SC stressed that “municipal corporations are mere creatures of Congress” which has the
power to “create and abolish municipal corporations” due to its “general legislative powers.” The
SC said that the principle of local autonomy under the 1987 Constitution simply means
“decentralization” and such provision does not make local governments sovereign within the
state or an “imperium in imperio.” An LGU is a political subdivision of a nation or state which is
constituted by law and has substantial control of local affairs. In a unitary system of government,
such as the government under the Philippine Constitution, local governments can only be an intra
sovereign subdivision of one sovereign nation, it cannot be an imperium in imperio. Local
government in such a system can only mean a measure of decentralization of the function of
government. As to what state powers should be “decentralized” and what may be delegated to
local government units remains a matter of policy, which concerns wisdom. Congress, therefore,
has the power of control over Local governments. And if Congress can grant the City of Manila
the power to tax certain matters, it can also provide for exemptions or even take back the power.
The SC also added that local governments have no power to tax instrumentalities of the National
Government. PAGCOR is a government owned or controlled corporation with an original charter,
PD 1869. All of its shares of stocks are owned by the National Government. Otherwise, its
operation might be burdened, impeded or subjected to control by a mere Local government.
 Limbona vs. Mangelin
G.R. No. 80391
28 February 1989

FACTS: Limbona, was elected Speaker of the Regional Legislative Assembly or Batasang Pampook
of Central Mindanao (Assembly). On October 21, 1987 Congressman Datu Guimid Matalam,
Chairman of the Committee on Muslim Affairs of the House of Representatives, invited petitioner
in his capacity as Speaker of the Assembly of Region XII in a consultation/dialogue with local
government officials. Petitioner accepted the invitation and informed the Assembly members
through the Assembly Secretary that there shall be no session in November as his presence was
needed in the house committee hearing of Congress. However, on November 2, 1987, the
Assembly held a session in defiance of the Limbona’s advice, where he was unseated from his
position. Petitioner prays that the session’s proceedings be declared null and void and be it
declared that he was still the Speaker of the Assembly.

ISSUE: WON the autonomy granted to ARMM is decentralization of power?

RULING: No. The SC ruled that it is only a decentralization of administration. The SC discussed
that autonomy is either decentralization of administration or decentralization of power. There is
decentralization of administration when the central government delegates administrative
powers to political subdivisions in order to broaden the base of government power and in the
process to make local governments more responsive and accountable. At the same time, it
relieves the central government of the burden of managing local affairs and enables it to
concentrate on national concerns. The President exercises general supervision over them, but
only to ensure that local affairs are administered according to law. He has no control over their
acts in the sense that he can substitute their judgments with his own. Decentralization of power,
on the other hand, involves an abdication of political power in the favor of local governments
units declared to be autonomous. In that case, the autonomous government is free to chart its
own destiny and shape its future with minimum intervention from central authorities.
Decentralization of power amounts to self-immolation, since in that event, the autonomous
government becomes accountable not to the central authorities but to its constituency.

The SC concluded that the very Presidential Decree creating the autonomous governments of
Mindanao was never meant for decentralization of power but only of administration.

As to the petition, it was granted by the SC and it ruled that based on the facts presented, the
November 2 and 5, 1987 sessions were invalid.