and has an annual income that already exceeds that of many existing lower-income cities. This has been among the cases made against the cityhood bids of many high-income and populous municipalities surrounding Metro Manila, most notably Bacoor and Dasmariñas (which finally became cities in June 2012 and November 2009 respectively), which for many years have been more qualified to become cities than others. In response to the rapid increase in the number of municipalities being converted into cities since the enactment of the Local Government Code in 1991, Senator Aquilino Pimentel authored what became Republic Act No. 9009 in June 2001 which sought to establish a more appropriate benchmark by which municipalities that wished to become cities were to be measured. The income requirement was increased sharply from 20 million to 100 million in a bid to curb the spate of conversions into cities of municipalities that were perceived to have not become urbanized or economically developed enough to be able to properly function as a city. Despite the passage of RA 9009, 16 municipalities not meeting the required locally generated income were converted into cities in 2007 by seeking exemption from the income requirement. This led to vocal opposition from the League of Cities of the Philippines against the cityhood of these municipalities, with the League arguing that by letting these municipalities become cities, Congress will set "a dangerous precedent" that would not prevent others from seeking the same "special treatment". More importantly, the LCP argued that with the recent surge in the conversion of towns that did not meet the requirements set by RA 9009 for becoming cities, the allocation received by existing cities would only drastically decrease because more cities will have to share the amount allotted by the national government, which is equal to 23% of the IRA, which in turn is 40% of all the revenues collected by the Bureau of Internal Revenue. The resulting legal battles resulted in the nullification of the city charters of the 16 municipalities by the Supreme Court in August 2010. (See #"League of 16" and legal battles) Changing city status Throughout the years there have been instances of changes to the city's status with regard to eligibility for provincial elections, as a result of the passage of laws, both of general effectivity and specific to a city. Before 1979 Prior to 1979, all cities were just considered chartered cities,