ARTICLE X Likewise, Section 1 also provided protection of autonomous
regions. There were two autonomous regions that were supposed to be
LOCAL GOVERNMENT
GENERAL PROVISIONS:
Section 1. The territorial and political subdivisions of the Republic of the
Philippines are the provinces, cities, municipalities, and barangays. There shall
be autonomous regions in Muslim Mindanao and the Cordilleras as hereinafter
provided.
Section 1 consists of 2 parts: The first sentence which defines the local
government units as a whole and in general; and the second
sentence which defines the 2 autonomous regions that were created or
supposed to have been created by the 1987 constitution.
For the 1st time, the constitution defines the territorial and political
subdivisions of the Philippines. Previous to constitutional provision, it
was statutory – the provinces, the municipalities/cities, barangays.
Before that, there was already barangay law – that was only statutory in
which recognized the barangay.
A sitio no matter how important it is to a barangay is not a political
subdivision.
It must be remembered that in a unitary system of government such as
the Philippines, local government can only be intra-sovereign subdivision
of one sovereign nation because it is a unitary government; hence there
is only one government. The political subdivisions enumerated in Section
1(1st par.) are merely part of one sovereign nation.
So that local government can only mean and make sure of autonomy
and decentralization of functions of the national government
Section 1 recognizes the territorial and political subdivisions of the
Republic of the Philippines as the provinces, cities, municipalities, and
barangays. In barangays, the law that there are sitios and brooks, in the
local level on the ground is recognized but not insofar as the territorial
subdivision is concerned. It is only up to barangay level.
IA – ARTICLE X (Local Government)
formed under the 1987 constitution, to wit: (1) Muslim Mindanao region;
(2) Cordillera region.
The territorial and political subdivisions of the Republic of the Philippines
are: (1) Provinces; (2) Cities; (3) Municipalities; and (4) Barangays
There shall be autonomous regions in Muslim Mindanao and Cordilleras
as provided in the Constitution. (Section1)
Significance of Section 1: The constitutional significance of Section 1 is
that provinces, cities and municipalities and barangays have been fixed
as the standard territorial and political subdivisions of the Philippines.
This manner of subdividing the Philippines cannot go out of
existence except by a constitutional amendment
SECTION 2. The territorial and political subdivisions shall enjoy local autonomy.
The framers of the 1987 constitution had to insert section 2 because in
the later part of the article that is in the discussion of the 2 autonomous
regions, the autonomy that is given to these 2 autonomous regions is
enormous, that is wide ranging, which is not given to ordinary LGUs.
Therefore, Sec. 2 is an assurance to the LGUs that local autonomy shall
not be for mostly Mindanao and Cordilleras only but for all LGUs,
although autonomy for LGUs in general is less than that of the
Autonomous regions. On the other hand, the local autonomy that is
promised in Sec. 2 is found in the Local Gov’t Code; therefore, the local
autonomy that is given to LGUs outside of the autonomous regions will
be that what is found in the LGC.
The one that is constantly tested is the extent of the autonomy that is
being granted by the constitution.
What kind of autonomy is granted by the constitution? In the Local
Government Code that was crafted by virtue of the mandate of the
constitution, there was supposed to be also local autonomy for provinces
and political territorial subdivisions not only Muslim Mindanao.
Because, in Muslim Mindanao and in Cordilleras, the Constitution laid
down the powers that were supposed to be given to autonomous
1
regions: (1) power to share in the wealth; (2) self-governance; (3) they
have their own legislature; (4) they have their own executive; (5) they
have governors for provinces and yet they have another governor for
autonomous region and (6) have autonomous legislative body. But,
these powers were provided in detail in the constitution; however,
insofar as the other political and territorial subdivision is concerned
Section 2 took care of it. And, Section 2 provided that the territorial
and political subdivisions shall enjoy local autonomy.
There are two provisions of the Constitution that explicitly stated that
there should be local autonomy, to wit:
1) Section 1 – autonomous regions in Muslim Mindanao and the
Cordilleras and the Constitution laid down the basis for this
autonomy;
2) Section 2 – there shall be autonomy not only in Muslim
Mindanao and Cordilleras but also in territorial and political
subdivisions (provinces, cities, municipalities, barangays) but
then the extent of autonomy is not provided by the Constitution.
NOTE: The autonomy for local governments runs short of a full
autonomy that is being given to autonomous regions – self-governance
and others. Ergo, autonomy for local governments would only be
decentralization of administration as against the concept of
decentralization of power. Autonomy that is being given to local
government units not the autonomous regions would only be
decentralization of administration.
2 KINDS OF DECENTRALIZATION:
Decentralization of Administration – there is decentralization of
administration when the central government delegates administrative
powers to political subdivisions in order to broaden the base of
governmental power and in the process to make local governments
“more responsive and accountable’ and “ensure their fullest
developments as self-reliant communities and make them more effective
partners in the pursuit of national development and social progress.”
IA – ARTICLE X (Local Government)
This is for purposes of control but it is still unitary – there’s central or the
hold that is not to be decentralized as against the decentralization of
power which involves an abdication of political power in favour of local
government units declared to be autonomous. (Given to Muslim
Mindanao region and the Cordilleras)
There’s still grey area for the meaning of local autonomy to local
government units. In the case of San Juan v. Civil Service
Commission, it involves the appointment of Provincial Budget Officer
(PBO). PBO is supposed to be nominated by the provincial governor and
appointed by the National – stated in law. Supreme Court said that
should be the case – there should be decentralization, it should be from
local government units.
SAN JUAN vs. CSC, p. 1115-1116: The issue in San Juan was the
authority to appoint a PBO. By EO No. 112, the authority had been given
to the Secretary of Budget Management “upon recommendation of the
local executive concerned.” The person recommended by the provincial
governor, however, did not possess the necessary qualifications. Hence,
the Budget Secretary appointed somebody else of his own choice. The
Court ruled that if the recommendee of the local executive is not
qualified, the Secretary must ask for new recommendees with the
necessary eligibility. Concluding, the Court said: “our national officials
should not only comply with the constitutional provisions on local
autonomy but should also appreciate the spirit of liberty upon
which these provisions are based.
Q: The law says that the budget officer shall be appointed by the
Department head upon the recommendation of the head of local
government subject to civil service rules and regulations. If none of those
recommended by the local government head meets the requirements of
law, may the Department head appoint anyone he chooses?
A: No, he must return the recommendations of the local government
head explaining why the recommendees are not qualified and ask for a
new recommendation. In other words, the recommendation of the local
government head is a condition sine qua non of the Department’s
appointing authority. This is the only way local autonomy can be given by
recognition the Constitution wants it to have. When in doubt, favour
autonomy. (San Juan v. CSC, 1991)
2
However, in the case of Magtajas v. Pryce Properties, Cagayan de Oro
City passed an ordinance prohibiting the PAGCOR from operating in
their City. The case reached the Supreme Court and it said that
ordinances should not contravene statutes. The City ordinance
prohibiting the operation of the PAGCOR in CDO must conform to
the statute which is the establishment of the PAGCOR. Municipal
governments are only the agents of national government.
ISSUE: Whether or not the LGU of Cagayan de Oro can prohibit
PAGCOR from operating a casino – NO
MAGTAJAS v. PRYCE PROPERTIES, p. 1113-1114: the government of
CDO City contended that, under its authority to prohibit gambling, the city
could prevent the PAGCOR from operating a casino in the City.
PAGCOR, however, had authority under PD No. 1869 to centralize and
regulate all games of chance under the territorial jurisdiction of the
Philippines. In ruling that CDO City could not curtail PAGCOR’s
authority, the Court in no uncertain terms said: “The rationale of the
requirement that the ordinances should bot contravene a statute is
obvious. Municipal governments are only agents of the national
government. Local councils exercise only delegated legislative
powers conferred on them by Congress as the national lawmaking
body. The delegate cannot be superior to the principal or exercise
powers higher than those of the latter.
Ordinance contrary to statute held invalid. The ordinance prohibiting
the issuance of a business permit to, and cancelling any business permit
of any establishment allowing its premises to be used as a casino, and
the ordinance prohibiting the operation of a casino, were declared invalid
for being contrary to PD 1869 (Charter of PAGCOR)which has the
character and force of a statute.
This basic relationship between the national legislature and the local
government units has not been enfeebled by the new provisions in the
Constitution strengthening the policy of local autonomy. Without meaning
to detract from that policy, we here confirm that Congress retains
control of the local government units although in significantly
reduced degree now than under our previous Constitutions. The power
to create still includes the power to destroy. The power to grant still
includes the power to withhold or recall. xxx By and large, however, the
IA – ARTICLE X (Local Government)
national legislature is the principal of the local government units, which
cannot defy its will or modify or violate it.” (Magtajas v. Pryce Properties,
GR 111097, 07.20.94)
The same manner in Laguna Lake Development Authority (LLDA) v.
Court of Appeals, it strict the town around the Laguna de Bay the
construction or dismantling of fish pens because there is LLDA at that
time.
LLDA vs. CA, p. 1116: The SC denied to the municipalities around
Laguna Lake the power to authorize the construction or dismantling of
fishpens, fish enclosures, fish corrals, and the like in Laguna Lake. The
municipalities claimed the authority under the general provisions of the
1991 LGC, specifically Section 149. The LLDA, however, claimed power
under RA 4850 as amended by PD 813. Applying principles of
statutory construction, the Court ruled that the specific power of
the LLDA must prevail over the general power of local
governments. Moreover, the Court pointed out that the power given by
the LGC to local governments was revenue generating power and not a
regulatory power. Hence, the Court, while denying regulatory authority to
the municipalities, recognized their authority to impose fees for purposes
of generating revenue.
TAN v. PEREÑA, the municipality came up with an ordinance increasing
the number of cockpits and cockfights. But SC said that there is already
a statute that regulates the number of cockpits and cockfights.
While indeed the Constitution has expanded the autonomy of local
governments, they have not been thereby made imperium in imperio.
Congress may still impose limits on their powers. Thus, they may not
violate the statutory limits on the number of cockpits in a locality.
SECTION 3. The Congress shall enact a local government code which shall
provide for a more responsive and accountable local government structure
instituted through a system of decentralization with effective mechanisms of
recall, initiative, and referendum, allocate among the different local government
units their powers, responsibilities, and resources, and provide for the
qualifications, election, appointment and removal, term, salaries, powers and
functions and duties of local officials, and all other matters relating to the
organization and operation of the local units.
3
Section is a mandate for the Congress to enact a Local Government
Code (LGC) – which is already done. This LGC was trumpeted by
Pimentel, who was the principal author, as the autonomy of LGUs but it
ran short of full autonomy for LGUs. There still existing umbilical cord.
Umbilical Cord comes in the form of the IRA (Internal Revenue
Allotment). The IRA is still controlled by the National Government and it
is the NG that flows (?) back to the LGUs the money after it has been
divided. LGC provided a different system for LGUs. Under the LGC,
Vice-Governors and Vice-Mayors were given functions. The LGC created
a legislative body in LGUs headed by the Vice-Mayors, insofar as
municipalities are concerned; and the Vice-Governors, insofar as the
provinces are concerned – independent for each other.
The LGC created a new structure in the Local Government; it separated
the executive and the legislative for the first time; Mayor as the executive
and the Vice Mayor as the chairman or head of the legislative
The LGC also provided the qualifications, election, and the removal of
terms, salaries and etc. of the local officials of the LGUs. It also provided
an effective system of recall and initiative & referendum.
RECALL – is a system invented in the LGC pursuant to the mandate of
the constitution to give more chances for citizens to participate in
governance, it made easier the removal of LG officers; comes hand in
hand with the term of LG officials which is 3 years – shorter so that more
can participate
- An instrument for effecting official accountability; means a device
or procedure by which a public official’s tenure may be
terminated by popular vote. The official is removed before the
expiration of the term. Mas maganda sana ito kung yung term
nung official ay mas mahaba kasi pag mahaba at after 2years
nagsawa ka pwede mong i-recall.
- Recall could only be done one year after the election but not one
year before an election. Ergo, it could be done only on the
second year – making the provision useless.
IA – ARTICLE X (Local Government)
INITIATIVE & REFERENDUM – a process whereby the registered voters
of a local government unit may directly propose, enact, or amend any
ordinance. People can directly participate in law making.
SECTION 4. The President of the Philippines shall exercise general supervision
over local governments. Provinces with respect to component cities and
municipalities, and cities and municipalities with respect to component barangays
shall ensure that the acts of their component units are within the scope of their
prescribed powers and functions.
POWER OF GENERAL SUPERVISION – it is the power of the superior
officer to see to it that lower officers perform their functions in
accordance with law. It does not include the power to substitute one’s
judgment for that of a lower officer in matters where a lower officer has
various legal alternatives to choose from.
Provinces have general supervision over municipalities and cities.
Municipalities and cities have general supervision over barangays.
SECTION 5. Each local government unit shall have the power to create its own
sources of revenues and to levy taxes, fees, and charges subject to such
guidelines and limitations as the Congress may provide, consistent with the basic
policy of local autonomy. Such taxes, fees, and charges shall accrue exclusively
to the local governments.
Under the LGC, each local government unit shall have the power to
create its own sources of revenues and to levy taxes. It does not change
the doctrine that municipal corporations do not possess inherent powers
of taxation. These are delegated powers of taxation and specifically
provided which activity could be taxed by the local government. Outside
of that, there is no grant of such power.
Manila Electric Company v. Province of Laguna (Gr. No. 131359,
May 5, 1999) – under the now prevailing constitution, where there is
neither a grant nor a prohibition by statute, the tax power must be
deemed to exist although congress may provide statutory limitations and
guidelines.
4
SECTION 6. Local government units shall have a just share, as determined by
law, in the national taxes which shall be automatically released to them.
With respect to the Internal Revenue Allotment (IRA). It is the share of
the local government units from internal revenue taxes that is collected
by the National Government. There is a formula in which this IRA is
subdivided. There’s a “pie” – share for provinces, share for cities, and
share for municipalities and barangays. When there is an increase to the
ones who have a share to a “pie”, shares of the members of the “pie”
would decrease. That is why there was a prohibition to the creation of
cities for a time. There was an increase number of cities, share from IRA
decreases. In the same vein, if a city is calf from several municipalities,
the municipality would be removed as recipient of a share from the “pie”
– so there would be an increase to the share of municipalities.
Mandanas v. Ochoa (Gr. No. 199802, July 3, 2018) and Garcia v.
Ochoa (Gr. No. 208488, July 3, 2018) – the SC interpreted the basis for
the just share of LGUs under Sec. 6, Art. 10 of the Constitution as being
based on all National Taxes, and not only National Internal Revenue
Taxes. It has been interpreted and it has been followed since the 1987
Constitution and the LGC came into play or became effective that the
IRA consists only of internal revenues but now, the SC holds that it is not
the mandate of the constitution because the constitution says that “The
Local government units shall have a just share in the national taxes” not
in the National Internal Revenue Taxes.
Pimentel v. Aguirre (Gr. No. 132988, July 19, 2000) – the SC court
ruled that it is unconstitutional because the LGC as well as Sec. 6, Art.
10 provide the automatic release of the share of local governments in
national taxes.
SECTION 7. Local governments shall be entitled to an equitable share in the
proceeds of the utilization and development of the national wealth within their
respective areas, in the manner provided by law, including sharing the same with
the inhabitants by way of direct benefits.
Isabela and Ifugao are entitled to a share in the income of the Magat
Dam because it is a utilization of national wealth within Nueva Vizcaya,
Quirino and Nueva Ecija. These provinces are given a share in the
income of National Wealth Development.
IA – ARTICLE X (Local Government)
Fund Sources of Local Governments
1) Local taxes, fees, and charges
2) Its share in the national taxes
3) Its share in the proceeds of the utilization of natural resources
within their respective areas
4) Other “sources of revenues” which they may legitimately make
use of either in their public or governmental capacity, ot private
or proprietary capacity.
Scope of Power to Levy Taxes, fees and charges
 They are subject to such guidelines and limitations as Congress
may provide. However, such guidelines and limitations to be
imposed by Congress must not be such as to frustrate the “basic
policy of local autonomy.”
Local governments can either have shares from revenues accruing
through fees and charges or they can receive direct benefits such as
lower rates, e.g. for consumption of electricity generated within their
locality.
SECTION 8. The term of office of elective local officials, except barangay
officials, which shall be determined by law, shall be three years and no such
official shall serve for more than three consecutive terms. Voluntary renunciation
of the office for any length of time shall not be considered as an interruption in
the continuity of his service for the full term for which he was elected.
When will the three-term limit of local elective officials apply? The
local government official must have been elected three consecutive
times and he has fully served three consecutive terms. (Borja, Jr. vs.
COMELEC, Gr. No. 133495, Sept. 3, 1998)
Example: Nick de Leon served for 12 years. During his 1st, he was
elected as Vice-Mayor but the Mayor died. Thereafter, he took his oath
as Mayor under the principle of succession. Then after that, he ran three
times.
Note: The limitations do not apply to barangay officials whose term and
number of allowable terms may be set by law.
5
SECTION 9. Legislative bodies of local governments shall have sectoral
representation as may be prescribed by law.
SECTION 10. No province, city, municipality, or barangay may be created,
divided, merged, abolished, or its boundary substantially altered, except in
accordance with the criteria established in the Local Government Code and
subject to approval by a majority of the votes cast in a plebiscite in the political
units directly affected.
This is the new rule on the creation of Barangays.
Tan v. COMELEC (142 SCRA 727, July 11, 1986) – explained the
scope of the required plebiscite to mean that, if what is involved is a
barangay, the plebiscite should be municipality-wide or city-wide, and if a
municipality or component city, province-wide; and that if a portion of a
province is to be carved to form another province, the plebiscite should
include the mother province.
SECTION 11. The Congress may, by law, create special metropolitan political
subdivisions, subject to a plebiscite as set forth in Section 10 hereof. The
component cities and municipalities shall retain their basic autonomy and shall
be entitled to their own local executives and legislative assemblies. The
jurisdiction of the metropolitan authority that will hereby be created shall be
limited to basic services requiring coordination.
It is the basis for the creation of the MMDA (Metropolitan Manila
Development Authority). As mandated by the Constitution, the MMDA
was created to have cooperation affecting basic services among the
component cities and municipalities of Metro Manila. It does not involve
merging of political powers; each of the LGUs comprising the MMDA
retains their powers. It only exist to coordinate service and efforts that
affects the members of the MMDA.
SECTION 12. Cities that are highly urbanized, as determined by law, and
component cities whose charters prohibit their voters from voting for provincial
elective officials, shall be independent of the province. The voters of component
cities within a province, whose charters contain no such prohibition, shall not be
deprived of their right to vote for elective provincial officials.
The three (3) kinds of cities provided in Section 12, to wit:
1) Highly urbanized cities as may be determined by law
IA – ARTICLE X (Local Government)
2) Cities not raised to the highly urbanized category but whose
existing charters prohibit their voters from voting in provincial
elections ( i.e. Santiago City)
3) Component cities, i.e. cities which are under a province in some
way
The first 2 categories are independent of the province.
Santiago City is not highly urbanized and the charter of Santiago
prohibited its voters from voting provincial candidates.
Note: Cities in the 1st and 2nd categories do not vote in provincial
elections – they are independent of the province (includes incapacity of
its residents to run for provincial office); cities in the 3 rd category are
under a province, they cannot be denied a vote in the election of
provincial officials.
SECTION 13. Local government units may group themselves, consolidate or
coordinate their efforts, services, and resources for purposes commonly
beneficial to them in accordance with law.
The groupings may be done even without enabling law.
SECTION 14. The President shall provide for regional development councils or
other similar bodies composed of local government officials, regional heads of
departments and other government offices, and representatives from non-
governmental organizations within the regions for purposes of administrative
decentralization to strengthen the autonomy of the units therein and to accelerate
the economic and social growth and development of the units in the region.
Purpose of Section 14: to foster administrative decentralization as a
complement to political decentralization in order to make possible
bottom-to-top planning.
AUTONOMOUS REGIONS:
SECTION 15. There shall be created autonomous regions in Muslim Mindanao
and in the Cordilleras consisting of provinces, cities, municipalities, and
geographical areas sharing common and distinctive historical and cultural
heritage, economic and social structures, and other relevant characteristics
6
within the framework of this Constitution and the national sovereignty as well as
territorial integrity of the Republic of the Philippines.
This section gives the criteria for the creation of autonomous regions.
This is one of the criticisms of the late Miriam Defensor Santiago on the
initial version of the Bangsamoro Basic Law (BBL).
The purpose of the creation of the autonomous regions is the
creation of a situation which will allow each culture to flourish
unhampered by the dominance of other cultures and thereby to
contribute more effectively to national progress. Hence, a pre-requisite
for the creation of an autonomous region is a certain, distinctive, regional
commonality of historical and cultural heritage, economic and social
structures and other relevant characteristics - that is why ARMM was
initially envisioned to compose of provinces that are Muslim dominated.
There was also the creation of the Cordillera Administrative Region
(CAR) where at least 7 provinces of the Cordillera are envisioned to be
part of the Cordillera Autonomous Region but only Ifugao concurred to
the vision that is why it did not push through.
SECTION 16. The President shall exercise general supervision over
autonomous regions to ensure that the laws are faithfully executed.
SECTION 17. All powers, functions, and responsibilities not granted by this
Constitution or by law to the autonomous regions shall be vested in the National
Government.
Only those granted powers of autonomous regions will be exercised by
the autonomous regions.
Powers which are not given to autonomous regions (only for central
government). Autonomous Regions shall not have jurisdiction over:
1) national defense and security
2) Foreign relations and foreign trade
3) Customs and tariff
4) Quarantine
5) Currency
6) Monetary affairs
7) Foreign exchange
IA – ARTICLE X (Local Government)
8) Banking and quasi-banking
9) External borrowing
10) Posts and communications
11) Air and sea transport
12) Immigration and deportation
13) Citizenship and naturalization
14) General auditing
SECTION 18. The Congress shall enact an organic act for each autonomous
region with the assistance and participation of the regional consultative
commission composed of representatives appointed by the President from a list
of nominees from multisectoral bodies. The organic act shall define the basic
structure of government for the region consisting of the executive department
and legislative assembly, both of which shall be elective and representative of
the constituent political units. The organic acts shall likewise provide for special
courts with personal, family, and property law jurisdiction consistent with the
provisions of this Constitution and national laws.
The creation of the autonomous region shall be effective when approved by
majority of the votes cast by the constituent units in a plebiscite called for the
purpose, provided that only provinces, cities, and geographic areas voting
favorably in such plebiscite shall be included in the autonomous region.
This section is a mandate for congress to enact a law for the creation of
the autonomous regions – the ARMM and the CAR supposed to be.
Acting upon the mandate of the Constitution, the 1st Congress under the
1987 Constitution enacted an organic act for the autonomous regions. It
was submitted to the autonomous regions for plebiscite – because it was
provided in the organic acts that the provinces that would approve the
organic act would be the ones to form part of the ARs. There were 13
provinces that participated in the plebiscite that called for in the Organic
Act of Mindanao, only 5 provinces approved it. So the Autonomous
Region of Muslim Mindanao (ARMM) consists of 5 provinces. In the
Cordilleras there were 7/8 provinces who participated but only one (1)
approved the organic act.
RA 6734 is the organic act of Mindanao and RA 6776 was supposed to
be the organic act for the Cordilleras
7
SECTION 19. The first Congress elected under this Constitution shall, within maintained, supervised, and utilized in accordance with applicable laws. The
eighteen months from the time of organization of both Houses, pass the organic defense and security of the regions shall be the responsibility of the National
acts for the autonomous regions in Muslim Mindanao and the Cordilleras. Government

Preservation of peace and order shall be national in scope.

SECTION 20. Within its territorial jurisdiction and subject to the provisions of this
Constitution and national laws, the organic act of autonomous regions shall
provide for legislative powers over:
(1) Administrative organization;
(2) Creation of sources of revenues;
(3) Ancestral domain and natural resources;
(4) Personal, family, and property relations;
(5) Regional urban and rural planning development;
(6) Economic, social, and tourism development;
(7) Educational policies;
(8) Preservation and development of the cultural heritage; and
(9) Such other matters as may be authorized by law for the promotion of
the general welfare of the people of the region.

A constitutional provision likewise applicable to the Bangsamoro Basic

Law (BBL)

These are the suggested contents of an organic act.

The ancestral domain and natural resources are IPRA (Indigenous

People Rights Act). The act was filed by the late Congressman Lopez of
Davao City and in the 9th Congress (1992-1995) but it was not approved
because of the question on the ancestral domain. We did not know how
to deal with it. It was delayed until the 9th Congress ended/completed.
Cong. Lopez filed it again in the 10th Congress. We are hoping that we
could come up for a better definition of ancestral domain. Indigenous
people shall have rights over ancestral domain. What/Where is the
ancestral domain? Everything that was occupied before and used before
since time immemorial is for the indigenous people. Even the doctrine
that all lands belong to the State was ruined because of the IPRA law.
There was a question on ownership over parcel of lands – it is violation
of the doctrine that all lands belong to the State. The Supreme Court said
that it is an exception because their ownership came before the State.

SECTION 21. The preservation of peace and order within the regions shall be
the responsibility of the local police agencies which shall be organized,

IA – ARTICLE X (Local Government) 8