Guingona, Jr. vs. Gonzales G.R. No.

106971, March 1, 1993

Labels: Case Digests, Political Law

Facts: The mathematical representation of each of the political parties represented in

the Senate for the Commission on Appointments (CA) is as follows: LDP7.5; LP-PDPLABAN--.5; NPC2.5; LAKAS-NUCD1.5. The LDP majority in the Senate converted
a fractional half membership into a whole membership of one Senator by adding onehalf or .5 to 7.5 to be able to elect respondent Senator Romulo. In so doing, one other
partys fractional membership was correspondingly reduced leaving the latters
representation in the CA to less than their proportional representation in the Senate.

Issue: Whether or not there is a violation of Art. VI, Sec. 18

Held: The respondents claim to membership in the CA by nomination and election of

the LDP majority in the Senate is not in accordance with Sec. 18 of Art. VI of the
Constitution and therefore violative of the same because it is not in compliance with the
requirement that 12 senators shall be elected on the basis of proportional
representation of the political parties represented therein. To disturb the resulting
fractional membership of the political parties in the CA by adding together 2 halves to
make a whole is a breach of the rule on proportional representation because it will give
the LDP an added member in the CA by utilizing the fractional membership of the
minority political party, who is deprived of half a representation. The provision of Sec. 18
on proportional representation is mandatory in character and does not leave any
discretion to the majority party in the Senate to disobey or disregard the rule on
proportional representation.

The Constitution does not require that the full complement of 12 senators be elected to
the membership in the CA before it can discharge its functions and that it is not
mandatory to elect 12 senators to the CA. The overriding directive of Art. VI, Sec. 18 is
that there must be a proportional representation of the political parties in the
membership of the CA and that the specification of 12 members to constitute its
membership is merely an indication of the maximum complement allowable under the
Constitution. The act of filling up the membership thereof cannot disregard the mandate
of proportional representation of the parties even if it results in fractional membership in
unusual situations. Even if the composition of the CA is fixed by the Constitution, it can
perform its functions even if not fully constituted, so long as it has the required quorum.
Watkins v. United States (1957)
FACTS: John Watkins was convicted for refusing to answer questions of the House UnAmerican Activities Committee (HUAC) about people he believed were no longer

members of the Communist Party. He asked the Supreme Court to review his conviction
after it was affirmed by the Court of Appeals.

The Court's Decision

In a 6-1 decision, with two justices not participating, the Supreme Court held that the
congressional subcommittee had not given Watkins a fair opportunity to determine
whether he could lawfully refuse to answer questions, and that his conviction for
contempt of Congress was therefore invalid under the Fifth Amendment's Due Process
Clause.

Chief Justice Earl Warren wrote for the majority: The power of the Congress to conduct
investigations is inherent in the legislative process. But, broad as is this power of
inquiry, it is not unlimited. There is no general authority to expose the private affairs of
individuals without justification in terms of the functions of the Congress.
Investigations conducted solely for the personal aggrandizement of the investigators or
to 'punish' those investigated are indefensible.

Justice Thomas Clark dissented. He argued that the majority opinion did not appreciate
the actual way in which congressional committees operated. He concluded that Watkins
was properly questioned about matters that were legitimately within the scope of the
subcommittee's topics. So long as the object of a legislative inquiry is legitimate and
the questions propounded are pertinent thereto, it is not for the courts to interfere with
the committee system of inquiry. To hold otherwise would be an infringement on the
power given the Congress to inform itself, and thus a trespass upon the fundamental
American principle of separation of powers.

More on the Case

The rise of the House Un-American Activities Committee (HUAC) also gave rise to more
cases involving contempt of Congress citations. As Chief Justice Warren described in
Watkins: In the decade following World War II, there appeared a new kind of
congressional inquiry unknown in prior periods of American history. Principally this was
the result of the various investigations into the threat of subversion of the United States
Government. This new phase of legislative inquiry involved a broad-scale intrusion
into the lives and affairs of private citizens.It was during this period that the Fifth
Amendment privilege against self-incrimination was frequently invoked and recognized
as a legal limit upon the authority of a committee to require that a witness answer its
questions.

Although Watkins appeared to check the power of HUAC, Justice William O. Douglas
later wrote in his autobiography that the promise contained in the Watkins opinion was

not kept. [Other cases] gave the House Un-American Activities Committee broad
powers to probe a person's ideas and beliefs. In effect, they allowed the committee to
subpoena anyone who had criticized the committee, and to examine all facets of his life,
holding him up as a subversive or a traitor and, if he was man enough to defy the
committee, to see that he went off to jail for his contempt.

Jose Bengzon, Jr. vs Senate Blue Ribbon Committee

203 SCRA 767 Political Law Constitutional Law The Legislative Department
Inquiry in Aid of Legislation When not Allowed

It was alleged that Benjamin Kokoy Romualdez and his wife together with the
Marcoses unlawfully and unjustly enriched themselves at the expense of the Filipino
people. That they obtained with the help of the Bengzon Law Office and Ricardo Lopa
Corys brother in law, among others, control over some of the biggest business
enterprises in the country including MERALCO, PCI Bank, Shell Philippines and
Benguet Consolidated Mining Corporation.
Senator Juan Ponce Enrile subsequently delivered a privilege speech alleging that Lopa
took over various government owned corporations which is in violation of the Anti-Graft
and Corrupt Practices Act. Contained in the speech is a motion to investigate on the
matter. The motion was referred to the Committee on Accountability of Public Officers or
the Blue Ribbon Committee. After committee hearing, Lopa refused to testify before the
committee for it may unduly prejudice a pending civil case against him. Bengzon
likewise refused invoking his right to due process. Lopa however sent a letter to Enrile
categorically denying his allegations and that his allegations are baseless and
malicious.
Enrile subsequently took advantage of the Senates privilege hour upon which he
insisted to have an inquiry regarding the matter. The SBRC rejected Lopas and
Bengzons plea.
Claiming that the Senate Blue Ribbon Committee is poised to subpoena them and
require their attendance and testimony in proceedings before the Committee, in excess
of its jurisdiction and legislative purpose, in clear and blatant disregard of their
constitutional rights, and to their grave and irreparable damage, prejudice and injury,
and that there is no appeal nor any other plain, speedy and adequate remedy in the
ordinary course of law, Bengzon et al filed a petition for prohibition with a prayer for
temporary restraining order and/or injunctive relief against the SBRC.

ISSUE: Whether or not the inquiry sought by the SBRC be granted.

HELD: No, the inquiry cannot be given due course. The speech of Enrile contained no
suggestion of contemplated legislation; he merely called upon the Senate to look into a

possible violation of Sec. 5 of RA No. 3019, otherwise known as The Anti-Graft and
Corrupt Practices Act. In other words, the purpose of the inquiry to be conducted by the
Blue Ribbon Committee was to find out whether or not the relatives of Cory, particularly
Lopa, had violated the law in connection with the alleged sale of the 36 or 39
corporations belonging to Kokoy to the Lopa Group. There appears to be, therefore, no
intended legislation involved. Hence, the contemplated inquiry by the SBRC is not really
in aid of legislation because it is not related to a purpose within the jurisdiction of
Congress, since the aim of the investigation is to find out whether or not the relatives of
the President or Mr. Ricardo Lopa had violated Section 5 of RA No. 3019, the Anti-Graft
and Corrupt Practices Act, a matter that appears more within the province of the courts
rather than of the legislature. Besides, the Court may take judicial notice that Mr.
Ricardo Lopa died during the pendency of this case.

ROMERO V. ESTRADA (2009)

FACTS
Petitioners Romero II and other members of the Board of Directors of R-II Builders, Inc.,
were invited on an investigation with regards to the investment of Overseas Workers
Welfare Administration (OWWA) funds in the Smokey Mountain project. The said
investigation will aid the Senate in determining possible amendments of Republic Act
8042 other known as the Migrant Workers Act.
ISSUE
Whether the Senate Committees inquiry is sub judice to the subject raised at hand?
HELD
YES. As briefly stated in Arnualt vs. Nazareno;
The power of inquiry with process to enforce it is an essential and appropriate auxiliary
to the legislative function. A legislative body cannot legislate wisely or effectively in the
absence of information respecting the conditions which the legislation is intended to
affect or change; and where the legislative body does not itself possess the requisite
information which is not infrequently true recourse must be had to others who possess
it.
WHEREFORE, the petition is DENIED.

GARCILLANO vs. THE HOUSE OF REPRESENTATIVES, et.al G.R. No. 170338

December 23, 2008
Facts:
Tapes ostensibly containing a wiretapped conversation purportedly between the
President of the Philippines and a high-ranking official of the Commission on Elections
(COMELEC) surfaced. The tapes, notoriously referred to as the "Hello Garci" tapes,

allegedly contained the Presidents instructions to COMELEC Commissioner Virgilio

Garcillano to manipulate in her favor results of the 2004 presidential elections. These
recordings were to become the subject of heated legislative hearings conducted
separately by committees of both Houses of Congress.

Intervenor Sagge alleges violation of his right to due process considering that he is
summoned to attend the Senate hearings without being apprised not only of his rights
therein through the publication of the Senate Rules of Procedure Governing Inquiries in
Aid of Legislation, but also of the intended legislation which underpins the investigation.
He further intervenes as a taxpayer bewailing the useless and wasteful expenditure of
public funds involved in the conduct of the questioned hearings.

The respondents in G.R. No. 179275 admit in their pleadings and even on oral
argument that the Senate Rules of Procedure Governing Inquiries in Aid of Legislation
had been published in newspapers of general circulation only in 1995 and in 2006. With
respect to the present Senate of the 14th Congress, however, of which the term of half
of its members commenced on June 30, 2007, no effort was undertaken for the
publication of these rules when they first opened their session.

Respondents justify their non-observance of the constitutionally mandated publication

by arguing that the rules have never been amended since 1995 and, despite that, they
are published in booklet form available to anyone for free, and accessible to the public
at the Senates internet web page.

Issue: Whether or not publication of the Rules of Procedures Governing Inquiries in Aid
of Legislation through the Senates website, satisfies the due process requirement of
law.

Held:
The publication of the Rules of Procedure in the website of the Senate, or in pamphlet
form available at the Senate, is not sufficient under the Taada v. Tuvera ruling which
requires publication either in the Official Gazette or in a newspaper of general
circulation. The Rules of Procedure even provide that the rules "shall take effect seven
(7) days after publication in two (2) newspapers of general circulation," precluding any
other form of publication. Publication in accordance with Taada is mandatory to comply
with the due process requirement because the Rules of Procedure put a persons liberty
at risk. A person who violates the Rules of Procedure could be arrested and detained by
the Senate.

The invocation by the respondents of the provisions of R.A. No. 8792, otherwise known
as the Electronic Commerce Act of 2000, to support their claim of valid publication
through the internet is all the more incorrect. R.A. 8792 considers an electronic data
message or an electronic document as the functional equivalent of a written document
only for evidentiary purposes. In other words, the law merely recognizes the
admissibility in evidence (for their being the original) of electronic data messages and/or
electronic documents. It does not make the internet a medium for publishing laws, rules
and regulations.

Given this discussion, the respondent Senate Committees, therefore, could not, in
violation of the Constitution, use its unpublished rules in the legislative inquiry subject of
these consolidated cases. The conduct of inquiries in aid of legislation by the Senate
has to be deferred until it shall have caused the publication of the rules, because it can
do so only "in accordance with its duly published rules of procedure."

HERMINIO A. ASTORGA vs. ANTONIO J. VILLEGAS, ET AL.

Facts;
House bill No. 9266, defining the powers, rights and duties of the Vice Mayor of Manila
became a law under RA 4065 after both houses and the President signed it. However, it
was later on found out that the said law was not the same as the version approved by
the Senate as it was going thru its revision. With this finding, the Senate President and
the President himself sent out a statement saying they are withdrawing their signatures
from the House Bill No. 9266, therefore, it should not be considered as a law.

Issue;WON the petition for mandamus, injunction and/or prohibition with preliminary
mandatory and prohibitory injunction be granted and compel the respondents to comply
with the provisions of RA 4065.

Ruling;The Supreme Court recognized the withdrawal of the President and the Senate
Presidents' signatures from RA 4065 or House Bill 9266, therefore it did not become a
law. The temporary restraining order was also made permanent.The intent of the law
making body based on its journals prevailed over technicality of the legal process of
enacting a bill.

Neptali Gonzales vs Macaraig

Political Law Veto Power Inappropriate Provision in an Appropriation Bill
FACTS: Gonzales, together w/ 22 other senators, assailed the constitutionality of Corys
veto of Section 55 of the 1989 Appropriations Bill (Sec 55 FY 89, and subsequently of

its counterpart Section 16 of the 1990 Appropriations Bill (Sec 16 FY 90). Gonzalez
averred the following: (1) the Presidents line-veto power as regards appropriation bills
is limited to item/s and does not cover provision/s; therefore, she exceeded her authority
when she vetoed Section 55 (FY 89) and Section 16 (FY 90) which are provision; (2)
when the President objects to a provision of an appropriation bill, she cannot exercise
the item-veto power but should veto the entire bill; (3) the item-veto power does not
carry with it the power to strike out conditions or restrictions for that would be legislation,
in violation of the doctrine of separation of powers; and (4) the power of augmentation in
Article VI, Section 25 [5] of the 1987 Constitution, has to be provided for by law and,
therefore, Congress is also vested with the prerogative to impose restrictions on the
exercise of that power.

ISSUE: Whether or not the President exceeded the item-veto power accorded by the
Constitution. Or differently put, has the President the power to veto `provisions of an
Appropriations Bill.
HELD: SC ruled that Congress cannot include in a general appropriations bill matters
that should be more properly enacted in separate legislation, and if it does that, the
inappropriate provisions inserted by it must be treated as item, which can be vetoed by
the President in the exercise of his item-veto power. The SC went one step further and
rules that even assuming arguendo that provisions are beyond the executive power to
veto, and Section 55 (FY 89) and Section 16 (FY 90) were not provisions in the
budgetary sense of the term, they are inappropriate provisions that should be treated
as items for the purpose of the Presidents veto power.

PASCUAL vs. SECRETARY OF PUBLIC WORKS

110 PHIL 331
GR No. L-10405, December 29, 1960

"A law appropriating the public revenue is invalid if the public advantage or benefit,
derived from such expenditure, is merely incidental in the promotion of a particular
enterprise."

FACTS: Governor Wenceslao Pascual of Rizal instituted this action for declaratory
relief, with injunction, upon the ground that RA No. 920, which apropriates funds for
public works particularly for the construction and improvement of Pasig feeder road
terminals. Some of the feeder roads, however, as alleged and as contained in the
tracings attached to the petition, were nothing but projected and planned subdivision
roads, not yet constructed within the Antonio Subdivision, belonging to private
respondent Zulueta, situated at Pasig, Rizal; and which projected feeder roads do not
connect any government property or any important premises to the main highway. The

respondents' contention is that there is public purpose because people living in the
subdivision will directly be benefitted from the construction of the roads, and the
government also gains from the donation of the land supposed to be occupied by the
streets, made by its owner to the government.

ISSUE: Should incidental gains by the public be considered "public purpose" for the
purpose of justifying an expenditure of the government?

HELD: No. It is a general rule that the legislature is without power to appropriate public
revenue for anything but a public purpose. It is the essential character of the direct
object of the expenditure which must determine its validity as justifying a tax, and not
the magnitude of the interest to be affected nor the degree to which the general
advantage of the community, and thus the public welfare, may be ultimately benefited
by their promotion. Incidental to the public or to the state, which results from the
promotion of private interest and the prosperity of private enterprises or business, does
not justify their aid by the use public money.
The test of the constitutionality of a statute requiring the use of public funds is whether
the statute is designed to promote the public interest, as opposed to the furtherance of
the advantage of individuals, although each advantage to individuals might incidentally
serve the public.
Guingona, Jr. vs. Carague
G.R. No. 94571. April 22, 1991

FACTS:
The 1990 budget consists of P98.4 Billion in automatic appropriation (with P86.8 Billion
for debt service) and P155.3 Billion appropriated under RA 6831, otherwise known as
the General Approriations Act, or a total of P233.5 Billion, while the appropriations for
the DECS amount to P27,017,813,000.00.
The said automatic appropriation for debt service is authorized by PD No. 18, entitled
Amending Certain Provisions of Republic Act Numbered Four Thousand Eight Hundred
Sixty, as Amended (Re: Foreign Borrowing Act), by PD No. 1177, entitled Revising the
Budget Process in Order to Institutionalize the Budgetary Innovations of the New
Society, and by PD No.1967, entitled An Act Strengthening the Guarantee and
Payment Positions of the Republic of the Philippines on its Contingent Liabilities Arising
out of Relent and Guaranteed Loans by Appropriating Funds For The Purpose.
The petitioners were questioning the constitutionality of the automatic appropriation for
debt service, it being higher than the budget for education, therefore it is against Section
5(5), Article XIV of the Constitution which mandates to assign the highest budgetary
priority to education.

ISSUE: Whether or not the automatic appropriation for debt service is unconstitutional; it
being higher than the budget for education.

HELD:
No. While it is true that under Section 5(5), Article XIV of the Constitution Congress is
mandated to assign the highest budgetary priority to education, it does not thereby
follow that the hands of Congress are so hamstrung as to deprive it the power to
respond to the imperatives of the national interest and for the attainment of other state
policies or objectives.
Congress is certainly not without any power, guided only by its good judgment, to
provide an appropriation, that can reasonably service our enormous debtIt is not only
a matter of honor and to protect the credit standing of the country. More especially, the
very survival of our economy is at stake. Thus, if in the process Congress appropriated
an amount for debt service bigger than the share allocated to education, the Court finds
and so holds that said appropriation cannot be thereby assailed as unconstitutional
ROMULO L. NERI, petitioner vs. SENATE COMMITTEE ON ACCOUNTABILITY OF
PUBLIC OFFICERS AND INVESTIGATIONS, SENATE COMMITTEE ON TRADE AND
COMMERCE, AND SENATE COMMITTEE ON NATIONAL DEFENSE AND
SECURITY G.R. No. 180643, March 25, 2008

FACTS: On April 21, 2007, the Department of Transportation and Communication

(DOTC) entered into a contract with Zhong Xing Telecommunications Equipment (ZTE)
for the supply of equipment and services for the National Broadband Network (NBN)
Project in the amount of U.S. $ 329,481,290 (approximately P16 Billion Pesos). The
Project was to be financed by the Peoples Republic of China.
The Senate passed various resolutions relative to the NBN deal. In the September 18,
2007 hearing Jose de Venecia III testified that several high executive officials and power
brokers were using their influence to push the approval of the NBN Project by the
NEDA.
Neri, the head of NEDA, was then invited to testify before the Senate Blue Ribbon. He
appeared in one hearing wherein he was interrogated for 11 hrs and during which he
admitted that Abalos of COMELEC tried to bribe him with P200M in exchange for his
approval of the NBN project. He further narrated that he informed President Arroyo
about the bribery attempt and that she instructed him not to accept the bribe.

However, when probed further on what they discussed about the NBN Project, petitioner
refused to answer, invoking executive privilege. In particular, he refused to answer the
questions on:

(a) whether or not President Arroyo followed up the NBN Project,

(b) whether or not she directed him to prioritize it, and
(c) whether or not she directed him to approve.
He later refused to attend the other hearings and Ermita sent a letter to the senate
averring that the communications between GMA and Neri are privileged and that the
jurisprudence laid down in Senate vs Ermita be applied. He was cited in contempt of
respondent committees and an order for his arrest and detention until such time that he
would appear and give his testimony.

ISSUE: Are the communications elicited by the subject three (3) questions covered by
executive privilege?

HELD: The communications are covered by executive privilege

The revocation of EO 464 (advised executive officials and employees to follow and
abide by the Constitution, existing laws and jurisprudence, including, among others, the
case of Senate v. Ermita when they are invited to legislative inquiries in aid of
legislation.), does not in any way diminish the concept of executive privilege. This is
because this concept has Constitutional underpinnings.

The claim of executive privilege is highly recognized in cases where the subject of
inquiry relates to a power textually committed by the Constitution to the President, such
as the area of military and foreign relations. Under our Constitution, the President is the
repository of the commander-in-chief, appointing, pardoning, and diplomatic powers.
Consistent with the doctrine of separation of powers, the information relating to these
powers may enjoy greater confidentiality than others.
Several jurisprudence cited provide the elements of presidential communications
privilege:
1) The protected communication must relate to a quintessential and non-delegable
presidential power.
2) The communication must be authored or solicited and received by a close advisor
of the President or the President himself. The judicial test is that an advisor must be in
operational proximity with the President.

3) The presidential communications privilege remains a qualified privilege that may be

overcome by a showing of adequate need, such that the information sought likely
contains important evidence and by the unavailability of the information elsewhere by
an appropriate investigating authority.

In the case at bar, Executive Secretary Ermita premised his claim of executive privilege
on the ground that the communications elicited by the three (3) questions fall under
conversation and correspondence between the President and public officials necessary
in her executive and policy decision-making process and, that the information sought
to be disclosed might impair our diplomatic as well as economic relations with the
Peoples Republic of China. Simply put, the bases are presidential communications
privilege and executive privilege on matters relating to diplomacy or foreign relations.

Using the above elements, we are convinced that, indeed, the communications elicited
by the three (3) questions are covered by the presidential communications privilege.
First, the communications relate to a quintessential and non-delegable power of the
President, i.e. the power to enter into an executive agreement with other countries. This
authority of the President to enter into executive agreements without the concurrence of
the Legislature has traditionally been recognized in Philippine jurisprudence. Second,
the communications are received by a close advisor of the President. Under the
operational proximity test, petitioner can be considered a close advisor, being a
member of President Arroyos cabinet. And third, there is no adequate showing of a
compelling need that would justify the limitation of the privilege and of the unavailability
of the information elsewhere by an appropriate investigating authority.

Respondent Committees further contend that the grant of petitioners claim of executive
privilege violates the constitutional provisions on the right of the people to information
on matters of public concern.50 We might have agreed with such contention if petitioner
did not appear before them at all. But petitioner made himself available to them during
the September 26 hearing, where he was questioned for eleven (11) hours. Not only
that, he expressly manifested his willingness to answer more questions from the
Senators, with the exception only of those covered by his claim of executive privilege.

The right to public information, like any other right, is subject to limitation. Section 7 of
Article III provides:
The right of the people to information on matters of public concern shall be recognized.
Access to official records, and to documents, and papers pertaining to official acts,
transactions, or decisions, as well as to government research data used as basis for
policy development, shall be afforded the citizen, subject to such limitations as may be
provided by law.

GARCIA V. COMELEC
Sept. 30, 1994
FACTS: On May 24, 1993, petitioners filed a petition with the Sangguniang Bayan of
Morong to annul Pambansang Kapasyahan Blg. 10, Serye 1993 which includes the
Municipaloty of Morong as part of the Subic Special Economic Zone in accord with the
RA No. 7227.
The municipality did not take any action on the petition within 30 days after its
submission; so, they resorted to their power of initiative under the Local Government
Code of 1991. They solicited the required number of signatures to repeal the said
resolution.
However, the Vice Mayor, Hon. Edilberto de Leon, and the Presiding Office of the
Sangguniang Bayan ng Morong wrote a letter dated June 11, 1993 to deny the petition
for local initiative and/or referendum.
On July 6, 1993, the Comelec denied the petition for local initiative because its subject
is merely a resolution and not an ordinance.

ISSUE: WON the Pambansang Kapasyahan Blg. 10, Serye 1993 is the proper subject
of an initiative?
Sub-issue: w/n the decision of the Comelec to deny the petition be set aside?

HELD:
The petition is granted and the decision of the Comelec on July 6, 1993 is annulled and
set aside.

RULING:
The 1987 Constitution installed back the power to the people regarding legislation
because of the event in February 1986. The new Constitution became less trusting of
public officials.
Through initiative, the people were given the power to amend the Constitution under
Sec. 2 Art. 17 which provides amendments to this Constitution may likewise be directly
proposed by the people through initiative upon a petition of at least 12% of the total
number of registered voters, of which every legislative district must be represented by at
least 3% of the registered voter therein.
The Comelec was also empowered to enforce and administer all laws and regulations
relative to the conduct of an initiative and referendum.

On Aug. 4, 1989, the Congress approved RA No. 6735 entitled An Act Providing for a
System of Initiative and Referendum and Appropriating Funds Therefor.
YES. Sec. 32 of Art. 6 provides the Congress shall provide for a system of initiative
and referendum, and the exceptions therefrom, whereby the people can directly
propose and enact laws or approve or reject any act or law or part thereof passed by
the Congress or local legislative body.
Under Sec. 32(a) of RA No. 6735 it provided the 3 systems of initiative, namely:
1.

Initiative on the Constitution petition to amend the Constitution

2.

Initiative on statutes petition proposing to enact a national legislation

3.
Initiative on local legislation petition proposing to enact a regional, provincial,
city, municipal, or barangay law, resolution or ordinance
Under its Sec.16(a), it provided the limitations on local initiatives, which is the power of
local initiative shall not be exercised more than once a year.