There is an understandable appeal to the call for another congressional district in Benguet. Geography makes governance difficult. Communities are separated by terrain. Access remains uneven. These realities naturally lead to the question of whether representation should be expanded.
But constitutional representation is not granted based on difficulty. It is determined by law. And that raises a more important question. Does Benguet meet the legal standards required for another district?
The 1987 Constitution provides the starting point. As recognized by the Supreme Court:
“Section 3 of the Ordinance appended to the 1987 Constitution provides: ‘Any province that may be created, or any city whose population may hereafter increase to more than two hundred fifty thousand shall be entitled in the immediately following election to at least one Member or such number of members as it may be entitled to on the basis of the number of its inhabitants and according to the standards set forth in paragraph (3), Section 5 of Article VI of the Constitution.’”
This provision ties representation directly to population. It also introduces the requirement of a uniform and progressive ratio of population, a standard that aims to keep representation equitable across districts.
If that is the standard, where does Benguet stand?
With a population of roughly 460,000, dividing the province into two districts would already result in figures below the commonly accepted benchmark of around 250,000 per district. But the proposal goes further. It groups Sablan, Tuba, Itogon, Bokod, and Kabayan into a district with only 153,478 people.
Is that still consistent with a uniform and progressive ratio?
The Supreme Court has, in the past, taken a firm position on population requirements. In Aldaba v. COMELEC, it struck down a law creating a legislative district for Malolos City for failing to meet the required population. The Court emphasized that:
“The creation of legislative districts must be in accord with the constitutional requirement of proportional representation.”
It also rejected projected population figures, requiring instead actual census data. Representation, the Court made clear, cannot rest on estimates or expectations.
Given that, how would a district with 153,478 people be viewed?
Some point to Aquino III v. COMELEC as a possible basis for flexibility. In that case, the Court clarified that the 250,000 population threshold is not strictly applied to provinces in the same way it is to cities.
But does that mean any population level is acceptable?
The same ruling still upholds the constitutional requirement of a uniform and progressive ratio of population. That suggests that while there may be flexibility, there are still limits. The question then becomes whether a district of 153,478 approximates proportional representation or departs from it.
If one district in Benguet were set at that level, what happens to the balance? Would the remaining district carry a significantly larger population? And how would both compare to districts in other parts of the country, many of which serve 250,000 to 400,000 or more?
At what point does flexibility become distortion?
There is also the matter of precedent. In Aldaba, the Court did not hesitate to invalidate a law passed by Congress when it failed to meet constitutional standards. If that is the case, would a similar challenge arise here? And if it does, how likely is it that such a proposal would withstand judicial scrutiny?
Geography is often raised as justification. Benguet is mountainous. Its municipalities are dispersed. Access is difficult. These are valid concerns. But are they constitutional grounds for reapportionment, or are they issues better addressed through infrastructure and governance?
Other provinces offer a useful comparison. Cavite, Bulacan, Laguna, and Camarines Sur expanded their congressional districts after sustained population growth justified it. Their additional representation followed demographic reality.
At the same time, provinces such as Apayao, Ifugao, Mountain Province, and Kalinga remain single district provinces despite facing even greater geographic challenges than Benguet. If geography alone were sufficient, would these provinces not have been subdivided long ago?
Where, then, does Benguet fit?
Ultimately, the issue may not be whether Benguet deserves another district, but whether it is ready for one under the Constitution. If representation must follow population, and if proportionality must be preserved, then the numbers raise difficult questions.
And perhaps the most important question of all is this:
With these gaps in population and proportionality, will Congress pass it, and if it does, will the Supreme Court sustain it?
