Title
Farinas vs. Executive Secretary
Case
G.R. No. 147387
Decision Date
Dec 10, 2003
Petitioners challenged Section 14 of R.A. No. 9006, arguing it unconstitutionally repealed Section 67 of the Omnibus Election Code. The Supreme Court upheld the law, ruling it did not violate the single subject rule or equal protection clause, dismissing the petitions.

Case Summary (G.R. No. 117363)

Key Dates and Constitutional Basis

Decision context: Court resolution applied the 1987 Philippine Constitution (decision date falls after 1990). Key constitutional provisions invoked in the litigation include: Article VI, Section 26(1) (one subject in the title requirement for every bill), Article XI, Section 1 (public office as a public trust—referenced in prior jurisprudence upholding Section 67), and Article III, Section 1 (due process and equal protection). Statutory background includes Section 66 and Section 67 of the Omnibus Election Code and provisions of R.A. 9006 (Sections 2, 14, 16).

Legislative History of Republic Act No. 9006

R.A. 9006, titled to enhance free, orderly, honest, peaceful and credible elections through fair election practices, consolidated House Bill No. 9000 and Senate Bill No. 1742. A Bicameral Conference Committee (BCC) reconciled the two versions and submitted a report (Nov. 29, 2000). The House engaged in plenary debates on Feb. 5–7, 2001, including election and re-election of conferees and viva voce actions; the BCC report was eventually approved by both Houses and the measure was signed by the presiding officers of both chambers and certified as finally passed. The President signed the Act into law on Feb. 12, 2001. Section 14 of R.A. 9006 expressly repealed Section 67 of the Omnibus Election Code (and other provisions).

Substance of the Repealed Provision (Section 67) and Statutory Effect

Section 67 of the Omnibus Election Code had provided that any elective official, national or local (except President and Vice‑President), who files a certificate of candidacy for an office other than the one he or she holds in a permanent capacity shall be considered ipso facto resigned from the office upon filing. Section 14 of R.A. 9006 repealed Section 67 (as well as other provisions), thereby removing the ipso facto resignation consequence for elective officials filing candidacies for other elective offices.

Petitioners’ Principal Contentions

  1. One-subject–one-title violation (Section 26[1], Article VI): Petitioners argued Section 14 is a proscribed rider because the subject matter of R.A. 9006 (largely media access and fair election practices) dissimilarly addresses the limitation embodied in Section 67; repeal of Section 67 was not expressed in the title and thus exceeded the one-subject rule. 2) Equal protection violation: by repealing Section 67 but retaining Section 66 (which treats appointive officials as ipso facto resigned upon filing candidacy), R.A. 9006 allegedly discriminated against appointive officials and conferred disparate treatment without justification. 3) Enactment irregularities: alleged procedural and BCC irregularities in the House’s handling of the bicameral report, signatures, and final text warrant nullification of the entire Act. 4) Effectivity clause/due process: Section 16, making the Act effective upon approval, allegedly violated due process and publication requirements; petitioners contended that the law should not take immediate effect without required publication. 5) Substantive contention that Section 67 was sound law rooted in the constitutional accountability provision (Article XI, Section 1) and should not have been repealed.

Respondents’ Principal Defenses

  1. Standing: respondents initially contended petitioners lacked standing and did not demonstrate direct injury; also argued taxpayer standing was inapplicable. 2) Enrolled bill doctrine and procedural regularity: respondents invoked the enrolled bill doctrine—signatures of the presiding officers and certification by the secretaries of both Houses conclusively prove due enactment—and maintained alleged internal parliamentary irregularities do not permit judicial inquiry. 3) One-subject defense: respondents argued the Act’s broad title and objectives (fair election practices and ensuring equal opportunity in media access) encompass repeal of Section 67 as germane to leveling the electoral playing field; thus Section 14 is not a rider. 4) Equal protection defense: respondents asserted substantial distinctions between elective and appointive officials justify differential treatment—elective officials derive authority from the popular mandate and are allowed to participate in political activity, whereas appointive officials are (per civil service rules) restricted from partisan political activity—so the classification is reasonable. 5) Effectivity clause: respondents argued immediate effectivity does not deprive any person of due process as enforcement would require statutory formalities and adjudication; moreover, effectivity concern was premature absent enforcement. Respondents maintained that the Speaker and Secretary General acted within discretion in applying the statute.

Procedural Ruling on Standing (Locus Standi)

The Court adopted a liberal approach to standing given the matter’s nationwide significance and the imminent national elections. It recognized precedents allowing members of Congress to challenge statutes of overarching public importance. The Court therefore found petitioners had standing to invoke constitutional review, particularly since the issue affected the electoral process and would otherwise invite multiplicity of suits.

One-Subject–One-Title / Rider Analysis and Holding

Legal standard: the one-subject rule requires every bill to embrace only one subject and have that subject expressed in the title; the Court applies a reasonable, not technical, construction: the title need be comprehensive enough reasonably to include the general object, without enumerating every means. Application: the Court found the title and objectives of R.A. 9006 (promoting free, orderly, honest, peaceful and credible elections through fair election practices and ensuring equal opportunity and protection from harassment and discrimination for candidates) sufficiently encompassed the repeal of Section 67. Legislative deliberations and BCC records showed legislators expressly discussed and treated repeal of Section 67 as germane to leveling the playing field and fair election practices. The Court therefore held Section 14 is not a proscribed rider and does not violate Article VI, Section 26(1).

Equal Protection Analysis and Holding

Legal standard: equal protection tolerates reasonable classification; legislation is constitutional if it treats similarly situated persons alike and classifications rest on substantial distinctions. Application: the Court identified material and significant distinctions between elective and appointive officials: elective officials hold office by popular mandate for fixed terms and are expressly permitted to engage in political activity, while appointive officials are subject to civil service prohibitions on partisan activity and may serve at the pleasure of appointing authorities or have differing tenure protections. Given those differences and uniform treatment within each class, the Court held the retention of Section 66 and repeal of Section 67 do not violate equal protection.

Enrolled Bill Doctrine and Alleged Legislative Irregularities

Petitioners alleged multiple internal irregularities in the bicameral process and final enactment (multiple BCCs, missing signatures, lack of distribution of final text, disappearance of an amendment, change in effectivity clause). The Court applied the enrolled bill doctrine: certification by the presiding officers and secretaries of both Houses is conclusive of proper enactment. The Court refused to probe internal parliament

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