League of Cities vs.

House, 2008 FACTS: The petitioners filed for prohibition with prayer for the issuance of a writ of preliminary injunction or TRO assailing the constitutionality of the subject Cityhood Laws and enjoining the COMELEC and respondent municipalities from conducting plebisites pursuant to the Cityhood Laws. -11th Congress enacted into law 33 bills converting 33 municipalities into cities. However, it did not act on bills converting 24 others -12th Congress enacted RA 9009 effective June 30, 2001 amending the Local Government Code by increasing the annual income requirement from P20 million to P100 million for conversion of a municipality into a city -After RA 9009s effectivity, House of Reps of the 12th Congress adopted Joint Resolution 29 to exempt from the P100 million requirement the 24 municipalities whose bills were not approved in the 11th Congress. However, 12th Congress ended without the Senate approving Joint Resolution No. 29 -During the 13th Congress, House of Reps re-adopted Joint Resolution No. 29 but the Senate failed again to approve.16 of the 24 municipalities mentioned in the unapproved Resolution then filed individual cityhood bills. -The said bills lapsed into law (Cityhood Laws) after its approval in the Congress on Dec 2006 (House of Reps) and February 2007 (Senate) directing the COMELEC to hold plebiscite to determine if the respective constituents of the municipality approves the conversion -Petitioners filed the petition to declare the Cityhood Laws unconstitutional for violation of Sec. 10, Art. X of the Consti and the Equal Protection Clause MAIN ISSUES:

1. Whether the Cityhood Laws violate Section 10, Article X of the Constitution; and 2. Whether the Cityhood Laws violate the equal protection clause. HELD: YES. Petitions were granted. Issue on WON Senate is a continuing body was discussed under Deliberations of the 11th Congress on Unapproved Bills Inapplicable: Congress is not a continuing body. The unapproved cityhood bills filed during the 11th Congress became mere scraps of paper upon the adjournment of the 11th Congress. All the hearings and deliberations conducted during the 11th Congress on unapproved bills also became worthless upon the adjournment of the 11th Congress. These hearings and deliberations (under 11th Congress) cannot be used to interpret bills enacted into law in the 13th or subsequent Congresses. Section 123, Rule XLIV of the Rules of the Senate, on Unfinished Business, provides: All pending matters and proceedings shall terminate upon the expiration of one (1) Congress, but may be taken by the succeeding Congress as if presented for the first time. (Emphasis supplied) Similarly, Section 78 of the Rules of the House of Representatives, on Unfinished Business, states: Section 78. Calendar of Business. The Calendar of Business shall consist of the following: a. Unfinished Business. This is business being considered by the House at the time of its last adjournment. Its consideration shall be resumed until it is disposed of. At the end of the term of a Congress, all Unfinished Business are deemed terminated. (Emphasis supplied)

Thus, the deliberations during the 11th Congress on the unapproved cityhood bills, as well as the deliberations during the 12th and 13th Congresses on the unapproved resolution exempting from RA 9009 certain municipalities, have no legal significance. They do not qualify as extrinsic aids in construing laws passed by subsequent Congresses.