11/11/2025
The ๐๐ฏ ๐๐ข๐ฏ๐ค, during its session today, November 11, 2025, in an 8-5-2 Decision, with five Justices dissenting, and two taking no part, acted on the consolidated petitions in G.R. No. E-02002 (๐๐ข๐ค๐ข๐ญ๐ช๐ฏ๐ต๐ข๐ญ ๐ท. ๐๐ฆ๐ฏ๐ข๐ต๐ฆ); G.R. No. E-02010 (๐๐ข๐บ๐ข๐ฎ ๐ท. ๐๐๐๐๐๐๐); G.R. No. E-02142 (๐๐ถ๐ซ๐ช๐ช ๐ท. ๐๐ง๐ง๐ช๐ค๐ฆ ๐ฐ๐ง ๐ต๐ฉ๐ฆ ๐๐ณ๐ฆ๐ด๐ช๐ฅ๐ฆ๐ฏ๐ต); and G.R. No. E-02276 (๐๐ช๐ฅ๐ข๐ญ๐จ๐ฐ ๐ท. ๐๐น๐ฆ๐ค๐ถ๐ต๐ช๐ท๐ฆ ๐๐ฆ๐ค๐ณ๐ฆ๐ต๐ข๐ณ๐บ) by denying the consolidated petitions questioning the constitutionality of Republic Act No. 12232, which sets the term of office of barangay officials and members of the Sangguniang Kabataan (BSK) to four years.
Under the law, the next BSK elections will be held on the first Monday of November 2026 and every four years thereafter.
Accordingly, the elections set for December 1, 2025, have been rescheduled to November 2026. Incumbent officials shall remain in office until their successors are elected.
The petitions, filed by Romulo B. Macalintal ๐ฆ๐ต ๐ข๐ญ., argued that the law is invalid for failing to comply with the guidelines in postponing elections set in the 2023 case of ๐๐ข๐ค๐ข๐ญ๐ช๐ฏ๐ต๐ข๐ญ ๐ท. ๐๐๐๐๐๐๐. The petitions also claimed that the law violates the publicโs right to vote and unduly favors BSK officials.
In upholding the law, the SC, through the ๐ฑ๐ฐ๐ฏ๐ฆ๐ฏ๐ค๐ช๐ข of Associate Justice Jhosep Y. Lopez, ruled that Article X, Section 8 of the Constitution grants Congress the authority to set the term duration of barangay officials, who are not bound by the general three-year term limit that applies to other elective local officials. This legislative power is not merely permissive; it makes Congress the sole body empowered to define the term of office of barangay officials.
The SC clarified that RA 12232 is fundamentally a term-setting law for BSK officials, establishing a four-year term and prohibiting consecutive terms for the Sangguniang Kabataan officials. It is not a law postponing elections; the rescheduling of the elections is merely incidental.
Therefore, the Macalintal guidelines, which set out the parameters Congress must follow in postponing elections, do not apply to RA 12232.
The SC also ruled that the law does not violate the publicโs right to vote, as it neither abolishes nor indefinitely suspends the BSK elections. It simply changes the interval from three to four years.
Finally, the SC held that the RA 12232 is not discriminatory, in that a law treating barangay officials differently does not amount to undue favor or discrimination when such treatment is expressly allowed by the Constitution.
SC Senior Associate Justice Marvic M.V.F. Leonen and Associate Justices Alfredo Benjamin S. Caguioa, Henri Jean Paul B. Inting, Antonio T. Kho, Jr. and Maria Filomena D. Singh dissented, while Associate Justices Ramon Paul L. Hernando and Amy C. Lazaro-Javier took no part.
Read the full text of the Press Briefer at https://sc.judiciary.gov.ph/?p=155312.
A copy of the Decision will be uploaded to the SC website once available.
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