Case Digest (G.R. No. 222095)
Facts:
In an original petition for certiorari and prohibition filed on October 3, 1967 before the Supreme Court in Manila, Bara Lidasan, a resident, taxpayer, and qualified voter of one of the barrios of Parang, Cotabato, assailed Republic Act No. 4790, signed into law on June 18, 1966, and entitled “An Act Creating the Municipality of Dianaton in the Province of Lanao del Sur.” The Act’s text purported to detach twenty-one barrios—nine from the municipalities of Butig and Balabagan (Lanao del Sur) and twelve from Buldon and Parang (Cotabato)—to constitute the new Municipality of Dianaton in Lanao del Sur. Prompted by the impending 1967 elections, the Commission on Elections (COMELEC) adopted resolutions on August 15 and September 20, 1967, interpreting RA 4790 to include all twenty-one barrios, including the twelve in Cotabato, for precinct and registration purposes, and refusing to suspend the law’s operation. Lidasan prayed that RA 4790 be declared unconstitutional for violating theCase Digest (G.R. No. 222095)
Facts:
- Antecedents
- Republic Act No. 4790 was signed into law on June 18, 1966, as “An Act Creating the Municipality of Dianaton in the Province of Lanao del Sur.”
- The bill originated in the House of Representatives; only its title was read during all stages of deliberation.
- Contents of RA 4790 and Implementation
- Section 1 listed twenty-one barrios to form Dianaton:
- Nine barrios in the municipalities of Butig and Balabagan (Lanao del Sur).
- Twelve barrios in the municipalities of Buldon and Parang (Cotabato).
- Comelec Resolutions (Aug. 15 and Sept. 20, 1967) adopted an interpretation implementing the transfer of all twenty-one barrios for the 1967 elections.
- Petition and Proceedings
- Petitioner Bara Lidasan, a resident, taxpayer, and qualified voter of Parang, Cotabato, filed an original action for certiorari and prohibition.
- He prayed that RA 4790 be declared unconstitutional and that Comelec’s implementing resolutions be nullified, invoking Article VI, Section 21(1) of the Constitution.
Issues:
- Constitutional Compliance of Title
- Does RA 4790’s title violate the requirement that “no bill which may be enacted into law shall embrace more than one subject which shall be expressed in the title of the bill”?
- Standing
- Does petitioner as a resident, taxpayer, and voter of the affected barrios have a substantial legal interest to challenge RA 4790 and its implementation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)