Tobias v. Abalos

Tobias v. Abalos

G.R. No. L-114783 December 8, 1994

Bidin, J.

Facts:

                Petitioners assail 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.”

Prior to the enactment of the assailed statute, the municipalities of Mandaluyong and San Juan belonged to only one legislative district. Hon. Ronaldo Zamora, the incumbent congressional representative of this legislative district, sponsored the bill which eventually became R.A. No. 7675. President Ramos signed R.A. No. 7675 into law on February 9, 1994.

Pursuant to the Local Government Code of 1991, a plebiscite was held on April 10, 1994. The people of Mandaluyong were asked whether they approved of the conversion of the Municipality of Mandaluyong into a highly urbanized city as provided under R.A. No. 7675. The turnout at the plebiscite was only 14.41% of the voting population. Nevertheless, 18,621 voted “yes” whereas 7,911 voted “no.” By virtue of these results, R.A. No. 7675 was deemed ratified and in effect.

Issue:

                whether R.A. 7675 infringes Section 26(1), Article VI of the Constitution

Held:

                No. The creation of a separate congressional district for Mandaluyong is not a subject separate and distinct from the subject of its conversion.  Moreover, a liberal construction of the “one-title-one-subject” rule has been liberally adopted by the court as to not impede legislation (Lidasan v. Comelec).