Sunday, March 1, 2015

The Associative vs. Asymmetrical Relationship


The Bangsamoro Basic Law (BBL) has its noble vision: it seeks to provide an “antidote to the decades-long armed rebellion that brought so much economic hardship and suffering to the southern Philippines.” [1] Those pushing for the passage of the BBL believe that to have real progress in the area, there is a need to have more autonomy, i.e., less interference from the central government since the laws and policies of the central government have failed to address the real grievances and experiences of the region.[2]

This is not the first time the Autonomous Region of Muslim Mindanao (ARMM) has sought independence. In 2005, a Memorandum of Agreement on the Ancestral Domain (MOA-AD) was drafted and was set to be signed on August 5, 2008. This was the first time the term “Bangsamoro Juridical Entity” (BJE) was mentioned. The BJE would have had the "power to build, develop and maintain its own institutions inclusive of civil service, electoral, financial and banking, education, legislation, legal, economic, police and internal security force, judicial system and correctional institutions." The Supreme Court declared the MOA-AD (even before it was signed) to be unconstitutional for having the BJE in "associative relationship "with the central government. According to then Supreme Court Justice Conchita Carpio-Morales,[3] the “associative relationship” is characterized by shared authority and responsibility between two states wherein one merely delegates responsibilities to the other in order to maintain a middle ground between integration and independence (in citing Keitner and Reisman[4]); thus, it was held that this cannot be accommodated under the present constitution. 

Meanwhile, In drafting the BBL, the Transition Commission, noted the previous Supreme Court ruling and have thus adopted the term “asymmetrical relationship”[5] to describe the envisioned relationship of the Bangsamoro with the central government. Supreme Court Justice Marvic Leonen, explains such in his concurring opinion in the case of League of Provinces of the Philippines v. DENR[6] that the “asymmetrical relationship” means that "autonomous regions are granted more powers and less intervention from the national government; and that the Constitution grants them legislative powers over some matters, e.g. natural resources, personal, family and property relations, economic and tourism development, educational policies, that are usually under the control of the national government."[7] However, we must remember that even these powers are limited under the present constitution. In one case, the Supreme Court held that it was unconstitutional for an ARMM Regional Assembly to create or reapportion legislative districts since the power to do so was lodged with the national legislature, and was beyond what was previously enumerated.[8]

In reading the draft of the BBL, it is interesting to note that the law provides not only for its concurrent powers (with the central government) but also its exclusive powers. These include expropriation and eminent domain and the enactment of a Bangsamoro General Appropriation Act by the Bangsamoro Parliament—examples of powers that are exercised by the national executive and legislative branches. Given the cases decided by the Supreme Court and where they stand, it is likely that the BBL would also be deemed unconstitutional especially when, I believe, it goes beyond the asymmetric relationship (following the definition aforementioned).

However, the Transition Commission said in its Primer that it is empowered to propose changes to the constitution that will accommodate the BBL, if necessary. Inevitably (and unfortunately), this would mean that we would have to wait for more years before its ultimate attainment and application. 






[1] Judy T. Gulane. Policy Brief: Land Governance in the Bangsamoro. April 2014.
[2] Bangsamoro Transition Commission. A Primer on the Bangsamoro Transition Commission and the Bangsamoro Basic Law, February 2014.
[3] The Province of North Cotabato v. GRP Peace Panel, G.R. No. 183591, October 14, 2008
[4] C.I. Keitner and W.M. Reisman, FREE ASSOCIATION:  THE UNITED STATES EXPERIENCE, 39 Tex. Int'l L.J. 1 (2003).
[5] Bangsamoro Basic Law (BBL) draft, Article 6, Sect. 1.
[6] League of Provinces of the Philippines v. DENR, G.R. No. 175368, April 11, 2013.
[7] 1987 Constitution, Article X, Sect. 20
[8] Sema v. COMELEC, G.R. No. 177597, July 16, 2008

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