Trece Martires, Quezon City), most Philippine cities were originally incorporated to provide a form of localized civil government to an area that is primarily urban, which, due to its compact nature and different demography and local economy, cannot be necessarily handled more efficiently by more rural-oriented provincial and municipal governments. However, not all cities are purely areas of dense urban settlement. To date there are still cities with huge expanses of rural or wilderness areas and considerable non-urban populations, such as Calbayog,Davao, Puerto Princesa, and Zamboanga as they were deliberately incorporated with increased future resource needs and urban expansion, as well as strategic considerations, in mind. With the enactment of the 1991 Local Government Code, municipalities and cities have both become more empowered to deal with local issues. Regular municipalities now share many of the same powers and responsibilities as chartered cities, but its citizens and/or leaders may feel that it might be to their best interest to get a larger share of internal revenue allotment (IRA) and acquire additional powers by becoming a city, especially if the population and local economy has grown enough. On the other hand, due to the higher property taxes that would be imposed after cityhood, many citizens have become wary of their town's conversion into a city, even if the municipality had already achieved a high degree of urbanization and has an annual income that already exceeds that of many 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 November 2009 and June 2012), 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 PHP 20 million to PHP 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.[10 - The resulting legal battles resulted in the nullification of the city charters of the 16 municipalities by the Supreme Court as of August 2010.