Title
Tobias vs. Abalos
Case
G.R. No. 114783
Decision Date
Dec 8, 1994
Residents challenged R.A. 7675, converting Mandaluyong into a city and creating a new legislative district, alleging constitutional violations. SC upheld the law, ruling it valid and dismissing claims of gerrymandering and procedural flaws.
A

Case Digest (G.R. No. 114783)

Facts:

Robert V. Tobias, Ramon M. Guzman, Terry T. Lim, Gregorio D. Gabriel, and Roberto R. Tobias, Jr., Petitioners filed a constitutional challenge to Republic Act No. 7675, entitled "An Act Converting the Municipality of Mandaluyong into a Highly Urbanized City to be Known as the City of Mandaluyong," after its enactment and ratification in 1994. Prior to the law, the municipalities of Mandaluyong and San Juan comprised a single legislative district represented by Hon. Ronaldo Zamora, who sponsored the bill that became R.A. No. 7675. President Ramos signed the Act on February 9, 1994, and a plebiscite pursuant to the Local Government Code of 1991 was held in the City of Mandaluyong on April 10, 1994, at which 14.41% of the voting population turned out, 18,621 voted "yes" and 7,911 voted "no," and the Act was deemed ratified. The petitioners, asserting their standing as taxpayers and residents of Mandaluyong, challenged specifically Article VIII, Section 49 of R.A. No. 7675, which created a separate legislative district for the newly converted City of Mandaluyong and provided that the remainder of the former San Juan/Mandaluyong district would become the legislative district of San Juan. They alleged violations of the one subject-one bill rule under Article VI, Section 26(1), and of Article VI, Section 5(1) and (4) of the 1987 Constitution, contending that Section 49 effected an unconstitutional increase in the composition of the House of Representatives, preempted Congress’s reapportionment power, and was enacted without requisite census proof; they also argued that San Juan inhabitants should have participated in the plebiscite and that the Act amounted to *gerrymandering*. The case was brought before the Court en banc and was opposed by the Respondents, Hon. City Mayor Benjamin S. Abalos, City Treasurer William Marcelino, and the Sangguniang Panlungsod of Mandaluyong, with the Solicitor General defending the statute.

Issues:

Does Article VIII, Section 49 of Republic Act No. 7675 violate the one subject-one bill rule of Article VI, Section 26(1) of the 1987 Constitution by combining conversion to a highly urbanized city with the creation of a separate legislative district? Does Section 49 contravene Article VI, Section 5(1) and (4) of the 1987 Constitution by increasing the membership of the House of Representatives beyond the constitutional limit and by preempting Congress’s reapportionment power absent a showing of population by census? Were the inhabitants of San Juan improperly excluded from the plebiscite on R.A. No. 7675, and does the enactment constitute unlawful *gerrymandering*?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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