Tobias
vs Abalos, G.R.
No. L-114783 case brief summary
December
8, 1994
Facts:
Complainants, invoking their right as taxpayers
and as residents of Mandaluyong, filed a petition questioning the
constitutionality of Republic Act No. 7675, otherwise known as "An
Act Converting the Municipality of Mandaluyong into a Highly
Urbanized City to be known as the City of Mandaluyong." Before
the enactment of the law, Mandaluyong and San Juan belonged to the
same legislative district.
The
petitioners contended that the act is unconstitutional for violation
of three provisions of the constitution. First, it violates the one
subject one bill rule. The bill provides for the conversion of
Mandaluyong to HUC as well as the division of congressional district
of San Juan and Mandaluyong into two separate district. Second, it
also violate Section 5 of Article VI of the Constitution, which
provides that the House of Representatives shall be composed of not
more than two hundred and fifty members, unless otherwise fixed by
law. The division of San Juan and Mandaluyong into separate
congressional districts increased the members of the House of
Representative beyond that provided by the Constitution. Third,
Section 5 of Article VI also provides that within three years
following the return of every census, the Congress shall make a
reapportionment of legislative districts based on the standard
provided in Section 5. Petitioners stated that the division was not
made pursuant to any census showing that the minimum population
requirement was attained.
Issue:
(1)
Does RA 7675 violate the one subject one bill rule?
(2)
Does it violate Section 5(1) of Article VI of the Constitution on the
limit of number of rep?
(3)
Is the inexistence of mention of census in the law show a lack of
constitutional requirement?
Rulings:
The Supreme Court ruled that the contentions are devoid of merit.
With regards to the first contention of one subject one bill rule,
the creation of a separate congressional district for Mandaluyong is
not a separate and distinct subject from its conversion into a HUC
but is a natural and logical consequence. In addition, a liberal
construction of the "one title-one subject" rule has been
invariably adopted by this court so as not to cripple or impede
legislation.
The
second contention that the law violates the present limit of the
number of representatives, the provision of the section itself show
that the 250 limit is not absolute. The Constitution clearly provides
that the House of Representatives shall be composed of not more than
250 members, "unless otherwise provided by law”. Therefore,
the increase in congressional representation mandated by R.A. No.
7675 is not unconstitutional.
With
regards, to the third contention that there is no mention in the
assailed law of any census to show that Mandaluyong and San Juan had
each attained the minimum requirement of 250,000 inhabitants to
justify their separation into two legislative districts, unless
otherwise proved that the requirements were not met, the said Act
enjoys the presumption of having passed through the regular
congressional processes, including due consideration by the members
of Congress of the minimum requirements for the establishment of
separate legislative district
The
petition was dismissed for lack of merit.
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