Title
Chiongbian vs. Orbos
Case
G.R. No. 96754
Decision Date
Jun 22, 1995
A challenge to the constitutionality of Section 13, Article XIX of R.A. No. 6734 and E.O. No. 429, questioning the President's authority to merge and reorganize administrative regions in Mindanao, upheld by the Supreme Court as an executive power aimed at efficient governance.

Case Summary (G.R. No. 96754)

Petitioner Contentions

  1. § 13, Art. XIX of R.A. 6734 unconstitutionally delegates legislative power to the President without standards to guide the exercise of that power.
  2. The Act’s title does not express or embrace the grant of presidential power to “merge” regions.
  3. The President exceeded his authority by reorganizing regions unrelated to those affected by the plebiscite and by transferring regional centers (e.g., moving Region IX’s center from Zamboanga City to Pagadian City).

Respondent Contentions

  1. The power to merge or reorganize administrative regions is executive in nature, traditionally lodged in the President to facilitate general supervision over local governments (Art. X, Sec. 4) and control of executive departments (Art. VII, Sec. 17).
  2. Congress merely granted the President authority to “fill up” legislative details in light of changing administrative needs.
  3. The grant is germane to the Act’s title (“An Act Providing for an Organic Act for the Autonomous Region in Muslim Mindanao”) because regional reorganization is necessary for establishing the ARMM.
  4. The reorganization followed guidelines under P.D. No. 1416, as amended, which vests the President with continuing authority to reorganize the national government and its subdivisions.

Issues Presented

  1. Whether the power to merge administrative regions is legislative or executive and whether § 13, Art. XIX provides sufficient standards.
  2. Whether the power granted is fairly expressed in the statute’s title.
  3. Whether the grant extends beyond regions containing provinces or cities that participated in or voted for the ARMM plebiscite.
  4. Whether the power includes transferring a regional center.

Applicable Law

• 1987 Constitution (Art. VII, Sec. 17; Art. X, Sec. 4; Art. VI, Sec. 26[1])
• R.A. No. 6734, § 13, Art. XIX (Organic Act for ARMM)
• Executive Order No. 429 (1990) as amended by E.O. No. 439
• R.A. No. 5435 (1968), P.D. No. 1 (1972), and subsequent decrees reorganizing administrative regions
• P.D. No. 1416, as amended by P.D. No. 1772

Nature of Administrative Regions

Administrative regions are non-political, non-territorial groupings of contiguous provinces created for purposes of executive supervision and efficient delivery of field services. Since 1972, successive laws and decrees have granted the President authority to create, merge, or reorganize these regions in pursuit of simplicity, economy, and efficiency.

Delegation and Standards

The Court held that the power to merge administrative regions is executive, not legislative, and that the delegation is analogous to prior grants of reorganization power under R.A. 5435 and related decrees. A specific statutory standard need not be spelled out in the challenged provision if it is implied from the policy underpinning earlier legislation—namely, promoting simplicity, economy, efficiency, and effective public service.

Title Requirement

The constitutional mandate that every law embrace but one subject, expressed in its title, is liberally construed. A title need only broadly indicate the general subject. Here, reorganization of administrative regions is clearly germane to an Organic Act establishing a new autonomous region.

Scope of Presidential Authority to Merge and Reorganize

Section 13, Art. XIX provides that provinces and cities declining ARMM inclusion “shall remain in the existing administrative regions,” but qualifies this by expressly empowering the President to “merge the existing regions.” The Court interpreted “merge” to include regrouping contiguous provinces for administrative exigency, irrespective of plebiscite participation, so long as the exercise is rational and serves the purposes of effective administration. Petitioners did not challenge the rationality of the specific reorganization criteria applied in E.O. 429 (geography,

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