Case Digest (G.R. No. 114783) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Robert V. Tobias et al. v. Hon. City Mayor Benjamin S. Abalos et al. (G.R. No. 114783, December 8, 1994), petitioners Robert V. Tobias, Ramon M. Guzman, Terry T. Lim, Gregorio D. Gabriel, and Roberto R. Tobias, Jr., residents and taxpayers of Mandaluyong, challenged the constitutionality of 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.” Prior to its enactment, Mandaluyong and San Juan comprised a single legislative district represented by Hon. Ronaldo Zamora, the bill’s sponsor. President Ramos signed RA 7675 on February 9, 1994. Pursuant to the Local Government Code of 1991, a plebiscite was held on April 10, 1994 in which 14.41% of qualified voters turned out, yielding 18,621 affirmative and 7,911 negative votes, thereby ratifying the conversion. Article VIII, Section 49 of the statute provided that Mandaluyong would constitute its own legislative district, and the resi Case Digest (G.R. No. 114783) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Context
- Petitioners (Robert V. Tobias et al.) are residents and taxpayers of Mandaluyong challenging the constitutionality of Republic Act No. 7675.
- Respondents are the City Mayor, City Treasurer, and Sangguniang Panlungsod of Mandaluyong.
- Enactment of R.A. No. 7675 and Plebiscite
- R.A. No. 7675, entitled “An Act Converting the Municipality of Mandaluyong into a Highly Urbanized City,” was sponsored by Representative Ronaldo Zamora and signed into law on February 9, 1994.
- Article VIII, Section 49 of R.A. No. 7675 provides that Mandaluyong shall have its own legislative district, and that the remainder of the former San Juan/Mandaluyong district becomes the legislative district of San Juan.
- Pursuant to the Local Government Code, a plebiscite was held on April 10, 1994, with a 14.41% turnout; 18,621 voted “yes” and 7,911 voted “no,” ratifying the city conversion.
Issues:
- Whether Section 49 of R.A. No. 7675 violates the “one subject–one bill” rule under Article VI, Section 26(1) of the Constitution by embracing the separate subject of dividing the legislative district.
- Whether Section 49 contravenes Article VI, Section 5(1)’s limit on House membership and Section 5(4)’s reapportionment requirement based on census data.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)