Case Summary (G.R. No. 114783)
Facts and Procedural History
Republic Act No. 7675, converting Mandaluyong into a highly urbanized city (HUC) and creating separate legislative districts for Mandaluyong and San Juan, was signed on February 9, 1994. A plebiscite held on April 10, 1994, with 14.41% turnout, yielded 18,621 “yes” and 7,911 “no” votes, ratifying the law. Petitioners challenged Article VIII, Section 49 (creation of separate districts) on constitutional grounds before the Supreme Court en banc.
Applicable Constitutional Provisions
1987 Constitution, Article VI:
• Section 5(1): Limit of 250 representatives “unless otherwise provided by law”
• Section 5(3): “Each city with a population of at least two hundred fifty thousand…shall have at least one representative”
• Section 5(4): Mandatory reapportionment within three years after every census
• Section 26(1): “Every bill passed by Congress shall embrace only one subject”
One Subject–One Bill Rule
Petitioners argued that RA 7675 unlawfully embraced two subjects: city conversion and district division, violating Article VI, Section 26(1). The Court applied a liberal construction: the title (“Converting the Municipality of Mandaluyong into a Highly Urbanized City of Mandaluyong”) sufficiently informs stakeholders of all germane provisions, including representation, under Sumulong v. Comelec and Lidasan v. Comelec. District creation was held to be a natural consequence of city conversion.
Legislative District Creation as Natural Consequence
Under Article VI, Section 5(3), a city with ≥250,000 population must have its own representative. Since RA 7675 statutorily attested that Mandaluyong met this threshold, separate district creation was constitutionally mandated and germane to the law’s subject.
Population and Census Requirements
Petitioners contended that RA 7675 lacked an explicit census showing each municipality’s population and thus contravened Sections 5(3) and (4). The Court invoked the presumption of regularity in congressional proceedings: it is not necessary for a law to recite all data considered; Congress is presumed to have evaluated population figures before enactment.
Composition of the House
Challenged was the increase in representatives above the 250-member limit in Section 5(1). The Constitution itself provides for an exception: the House “shall be composed of not more than two hundred and fifty members, unless otherwise provided by law.” RA 7675, being a law duly enacted by Congress, lawfully increased representation.
Congressional Reapportionment
Petitioners asserted that Section 49 preempted Congress’s exclusive right under Section 5(4) to reapportion districts post-census. The Court found this argument untenable: Congress cannot preempt its own legislative authority by enacting a law it fully deliberated and approved.
Plebiscitary Participation
Petitioners argued San Juan residents should have participated in the plebiscite because t
...continue readingCase Syllabus (G.R. No. 114783)
Facts
- Petitioners, residents and taxpayers of Mandaluyong, challenged Republic Act No. 7675 as unconstitutional.
- Before RA 7675, Mandaluyong and San Juan shared one congressional district represented by Hon. Ronaldo Zamora.
- RA 7675, sponsored by Rep. Zamora, was signed into law on February 9, 1994.
- Plebiscite held April 10, 1994: 14.41% turnout, 18,621 “Yes” votes, 7,911 “No” votes; RA 7675 deemed ratified.
- Article VIII, Section 49 of RA 7675 provides separate legislative districts for the newly constituted City of Mandaluyong and for San Juan.
Challenged Provision (Art. VIII, Sec. 49, RA 7675)
- “As a highly-urbanized city, the City of Mandaluyong shall have its own legislative district with the first representative to be elected in the next national elections after the passage of this Act. The remainder of the former legislative district of San Juan/Mandaluyong shall become the new legislative district of San Juan with its first representative to be elected at the same election.”
Petitioners’ Constitutional Objections
- Violation of the “one subject–one bill” rule (Art. VI, Sec. 26(1)): law’s title addresses city conversion but Section 49 divides a legislative district.
- Breach of the composition limit of the House (Art. VI, Sec. 5(1)): creation of a new district allegedly increases members beyond 250.
- Preemption of Congress’s reapportionment power (Art. VI, Sec. 5(4)): district division enacted without census and ahead of mandated reapportionment.
The One Subject–One Bill Rule
- Petitioners: Section 49 treats a subject (district division) distinct from city conversion in the