Facts:

• Juan Sumulong, President of the political party Pagkakaisa ng Bayan, is the petitioner against the Commission on Elections (COMELEC).
• The case arose from a resolution by COMELEC, authorized by Section 5 of Commonwealth Act No. 657, allowing political parties to propose election inspectors.
• Pagkakaisa ng Bayan claimed an exclusive right to propose these appointments and sought to nullify the resolution.
• The petitioner argued that the requirement for a political party to have polled at least ten percent of the total votes in the preceding election was unconstitutional.
• This requirement was not expressed in the title of the Act, violating Article VI, Section 21(1) of the 1935 Constitution.
• The title of Commonwealth Act No. 657 is "An Act to reorganize the Commission on Elections."
• The Act reorganizes the Commission created under Commonwealth Act No. 607 and establishes it under Article X of the Constitution.
• The lower court ruled against the petitioner, prompting the appeal.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled that Section 5 of Commonwealth Act No. 657 is constitutional and does not violate the constitutional provision regarding the title of the Act.
• The Court affirmed COMELEC's decision, stating it acted within its...(Unlock)

Ratio:

• The Supreme Court reasoned that the constitutional requirement for the title of an act to express its subject should be interpreted reasonably, allowing necessary legislation to be enacted without undue interference.
• The provisions of Section 5 are relevant to the reorganization of the Commission on Elections, which is the subject expressed in the title of the Act.
• The requirement for a political party to have polled at least ten percent of the votes is a legitimate measure to ensure that only parties with ...continue reading