LANANG T. ALI, JR., SAMSODIN C. AMELLA, AND DATUAN M. MAGON,JR. vs. BANGSAMORO TRANSITION AUTHORITY PARLIAMENT, ABDULRAOF A. MACACUA, IN HIS CAPACITY AS THE INTERIM CHIEF MINISTER OF THE BANGSAMORO AUTONOMOUS REGION IN MUSLIM MINDANAO, AND COMMISSION ON ELECTIONS.
- G.R. Number: G.R. No. 271741
- Promulgated: 2025-09-30
- Ponente: ZALAMEDA, J.
Doctrine
## Facts of the Case Petitioners Lanang T. Ali, Jr., et al. (G.R. No. E-02219) and Abdullah G. Macapaar, et al. (G.R. No. E-02235) filed petitions for certiorari and prohibition challenging the constitutionality and validity of Bangsamoro Autonomy Act No. (BAA) 77, or the "Bangsamoro Redistricting Act of 2025." BAA 77, passed by the Bangsamoro Transition Authority (BTA) Parliament and signed into law on August 28, 2025, amended BAA 58 by redistricting parliamentary districts within the Bangsamoro Autonomous Region in Muslim Mindanao (BARMM) and reallocating seven seats previously assigned to the Province of Sulu, which was excluded from BARMM by a Supreme Court ruling in **Province of Sulu v. Medialdea**. The first regular election for the Bangsamoro Government was postponed from 2022 to October 13, 2025. BAA 77 was enacted and signed less than two months before this election, during the election period which began on August 14, 2025. Immediately after BAA 77's enactment, BTA Speaker Pangalian M. Balindong disavowed his signature, stating it was unauthorized. The Commission on Elections (COMELEC) initially postponed the printing of ballots due to BAA 77 but later proceeded, citing the impracticality of applying the new redistricting measure. This Court consolidated the petitions and issued a temporary restraining order (TRO) against the implementation and enforcement of BAA 77 on September 15, 2025, leading COMELEC to suspend all preparations for the BARMM Parliamentary Elections. Petitioners and COMELEC subsequently sought clarification from the Court regarding the impact of the TRO on the elections, with COMELEC stating it lacked a legal anchor to proceed with preparations given the legal uncertainty. ## Issues 1. Whether the petitions satisfy the requisites for judicial review. 2. Whether direct resort to the Supreme Court is justified. 3. Whether BAA 77 violates Article VII, Section 25(a) of the **Bangsamoro Organic Law** by embracing more than one subject in its title. 4. Whether BAA 77 is ineffective for alleged improper publication in violation of Article 2 of the Civil Code. 5. Whether there is insufficient time to prepare for the BARMM Parliamentary Elections under BAA 77. ## Decision / Rationale **Issue 1:** The petitions satisfy the requisites for judicial review. The Court found that **an actual case or controversy** exists because BAA 77 affects the petitioners' right to suffrage and could potentially disenfranchise registered voters. Petitioners have **legal standing** as registered voters in affected districts, and some are nominees of political parties, directly impacted by the redistricting measure. The constitutional questions were **raised at the earliest opportunity**, as petitions were filed immediately after BAA 77 took effect. Lastly, the **constitutionality of BAA 77 is the very lis mota** of the cases, as the Court cannot resolve the petitions without addressing this issue. **Issue 2:** Direct resort to the Supreme Court is justified. The Court reiterated the recognized instances allowing direct relief, including when there are genuine issues of constitutionality, transcendental importance, cases of first impression, and exigency. The Court found that BAA 77's constitutionality involves **genuine constitutional issues** that require immediate resolution, especially being the first case involving a redistricting measure under the **Bangsamoro Organic Law**. The lack of factual questions requiring evidence, combined with the urgency to resolve uncertainties before the elections, also justified direct resort. **Issue 3:** BAA 77 does not violate Article VII, Section 25(a) of the **Bangsamoro Organic Law**. The Court held that **Sections 3, 4, and 5 of BAA 77 relate to the reconstitution of the parliamentary districts** in the BARMM, which is the singular subject expressed in the title of the law. Applying a reasonable, not technical, interpretation of the "one subject-one title" rule (**Alalayan v.…
Facts
The Bangsamoro Transition Authority (BTA) enacted Bangsamoro Autonomy Act No. (BAA) 77 to redistrict parliamentary seats for the upcoming Bangsamoro Autonomous Region in Muslim Mindanao (BARMM) elections scheduled for October 13, 2025. This was necessary after a Supreme Court decision excluded the Province of Sulu from the BARMM, leaving seven parliamentary seats to be reallocated. Petitioners, who are registered voters and political party nominees, challenged the constitutionality of BAA 77, arguing among other things, that its passage during the election period and too close to the election date made its implementation impossible. The Commission on Elections (COMELEC) concurred, stating it lacked sufficient time to make the necessary preparations for a credible election under the new law.
Issues
1. Whether the requisites for judicial review and direct resort to the Supreme Court are met. 2. Whether BAA 77 is unconstitutional for violating the 'one subject-one title' rule, lacking proper publication, and contravening provisions of the Bangsamoro Organic Law concerning presidential appointment powers and gerrymandering. 3. Whether BAA 77 is invalid for altering election precincts during the prohibited period and for being enacted too close to the election, making it impossible for the COMELEC to implement.
Ruling
The Supreme Court granted the petitions, declaring BAA 77 unconstitutional and making the temporary restraining order against it permanent. The Court found that all requisites for judicial review were satisfied and that direct resort was justified due to the urgency and transcendental importance of the constitutional issues. While the Court found no violation of the 'one-title, one-subject' rule, it sided with the petitioners and the COMELEC that there was insufficient time for the COMELEC to implement the redistricting under BAA 77 and carry out all necessary preparations for a free, orderly, and credible election on October 13, 2025. Consequently, the Court ruled that the elections could not proceed under either BAA 77 (which is unconstitutional) or the previously repealed BAA 58.
Keywords
Bangsamoro Autonomy Act No. 77, Republic Act No. 11054 Bangsamoro Organic Law, Republic Act No. 11593, Republic Act No. 12123, Bangsamoro Autonomy Act No. 58, Article VII Section 10 Bangsamoro Organic Law, Article VI Section 5(3) Constitution, Section 5 Voter's Registration Act, Article II Section 26 Constitution, Article V Section 1 Constitution, Article VII Section 7(b) Bangsamoro Organic Law, Article XVI Section 2 Bangsamoro Organic Law, Article VII Section 20 Bangsamoro Organic Law, Rule 65 Rules of Court, Rule 58 Rules of Court, Gerrymandering, Political Question Doctrine, Void Ab Initio, Impossibilium Nulla Obligatio Est, Bangsamoro Parliamentary Elections