Cityhood Laws, all enacted after RA 9009'''s effectivity, "explicitly exempt respondent municipalities from the increased income requirement from 20 million to 100 million in Sec. 450 of the Local Government Code (LGC), as amended by RA 9009. Such exemption clearly violates Section 10, Article X of the Constitution and is thus patently unconstitutional. To be valid, such exemption must be written in the Local Government Code and not in any other law, including the Cityhood Laws." However, more than a year later, on December 22, 2009, acting on the appeal of the so-called League of 16 Cities (an informal group consisting of the sixteen local government units whose cityhood status had been reversed), the Supreme Court reversed its earlier ruling as it ruled that "at the end of the day, the passage of the amendatory law (regarding the criteria for cityhood as set by Congress) is no different from the enactment of a law, i.e., the cityhood laws specifically exempting a particular political subdivision from the criteria earlier mentioned. Congress, in enacting the exempting law/s, effectively decreased the already codified indicators." As such, the cityhood status of the said 16 LGUs was effectively restored. On August 24, 2010, in a 16-page resolution, the Supreme Court reinstated its November 18, 2008, decision striking down the cityhood laws, reducing once more the sixteen LGUs to the status of regular municipalities. The most recent development in the legal battles surrounding the League of 16 came on February 15, 2011. Voting 7–6, the Supreme Court (SC) ruled that 16 towns that became cities in 2007 can stay as cities. This was the fourth time the SC has ruled on the case, and the third reversal. It said the conversion of the 16 towns into cities met all legal requirements. Rejected cityhood Batangas (1965): A majority of the votes cast in the then-municipality of Batangas rejected cityhood in a plebiscite conducted on the same day as the 1965 Philippine general elections, as mandated by Republic Act No. 4586. The city would have been named Laurel City in honor of Jose P. Laurel, the president of the Japanese-sponsored Second Republic. The municipality of Batangas would later be converted into a city under the same name in 1969. Tarlac (1969): The city charter of Tarlac (Republic Act No. 5907) was approved on June 21, 1969. Cityhood was rejected in a plebiscite held on November 11, 1969, by