Case Digest (G.R. No. 173794) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Henry R. Giron v. Commission on Elections, Petitioner Henry R. Giron challenged the constitutionality of Sections 12 and 14 of Republic Act No. 9006, otherwise known as the Fair Election Act, before the Supreme Court en banc on January 22, 2013. Giron contended that Section 12’s rule on the treatment of votes for substituted candidates after the printing of official ballots and Section 14’s repeal of Section 67 of Batas Pambansa Blg. 881 (the Omnibus Election Code) were unrelated to the Act’s declared purpose of lifting the ban on political advertising and ensuring fair election practices, thus violating the one subject–one title requirement under Section 26(1), Article VI of the 1987 Constitution. The Commission on Elections, chaired by Jose Melo, opposed the petition, invoking the Court’s earlier ruling in Fariñas v. Executive Secretary. Almario E. Francisco, Federico S. Jong Jr., and Ricardo L. Baes Jr. intervened, echoing Giron’s arguments. No lower court proceedings were... Case Digest (G.R. No. 173794) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Posture
- Petitioner Henry R. Giron filed a special civil action for certiorari and prohibition against the Commission on Elections (COMELEC), challenging the constitutionality of Sections 12 and 14 of Republic Act No. 9006 (Fair Election Act).
- Petitioners-in-intervention Almario E. Francisco, Federico S. Jong Jr., and Ricardo L. Baes Jr. joined Giron, reiterating his arguments.
- Challenged Provisions and Allegations
- Section 12 (Substitution of Candidates) – provides that votes cast for substituted candidates after official ballots are printed are stray votes, with space on ballots for writing substitute names.
- Section 14 (Repealing Clause) – repeals Section 67 of the Omnibus Election Code, which ipso facto resigns elective officials upon filing candidacy for a different office.
- Giron’s Claim – the inclusion of these provisions violates Section 26(1), Article VI of the 1987 Constitution (“one subject–one title” rule), as they are unrelated to lifting the political advertisement ban, the purported main subject of RA 9006.
- Respondent’s Position and Prior Ruling
- Respondent COMELEC, represented by Chairperson Jose Melo, opposed the Petition, relying on this Court’s prior decision in Fariñas v. Executive Secretary, which upheld the breadth of RA 9006’s title and subject.
- Legislative History – Bicameral Conference Committee transcripts show Congress deliberately adopted a broad title (“Fair Election Act”) to encompass various “unfair election practices,” including substitution rules and the repeal of Section 67.
Issues:
- Constitutional Issue
- Does the inclusion of Sections 12 and 14 in RA 9006 violate the “one subject–one title” requirement under Section 26(1), Article VI of the 1987 Constitution?
- Subsidiary Consideration
- Whether petitioners have overcome the strong presumption of constitutionality afforded to legislative enactments.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)