Cordillera vs COA 181 SCRA 495


Facts

The constitutionality of E.O. 220 was assailed which created the Cordillera Administrative Region (CAR) on the ground that it pre-empts the enactment of an Organic Act by the Congress and the creation of autonomous region in the Cordillera conditional on the approval of the act through a plebiscite.

Issue

Whether or not CAR is a territorial and political subdivision?
Whether or not E.O 220 is unconstitutional?




Held

It was held that the CAR is not an autonomous region in Cordillera contemplated in the Constitution. It was created not as a public or political subdivision. It does not have a separate juridical personality like the provinces, cities or municipalities. It is neither vested with the powers granted to public corporations.

It was created by virtue of E.O. 220 primarily to coordinate the planning and implementation of programs and services in the covered areas. CAR in nature is a regional coordinating agency of the national government. E.O. 220 is not unconstitutional since the constitutional guarantee of local autonomy pertains to the administrative autonomy of the local government units through the decentralization of government authority. The creation of autonomous regions in Muslim Mindanao contemplates the grant of political autonomy and not just administrative autonomy for the ARMM. The purpose of CAR is to serve as a transitory coordinating agency that will prepare the stage for political autonomy for the Cordilleras. It does not diminish the local autonomy of the covered provinces and cities. The petition was dismissed for lack of merit. 

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