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Abalos Vs Sabio

The Supreme Court dismissed the petition challenging the constitutionality of Republic Act No. 7675, which converted Mandaluyong into a Highly Urbanized City and divided it from San Juan. The court ruled that the act did not violate the one subject one bill rule, the limit on the number of representatives, or the requirement for a census to establish separate legislative districts. The petitioners' claims were deemed without merit, and the law was presumed to have followed proper legislative processes.

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Love-Love Jeraldine Mondia Dalupines
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21 views2 pages

Abalos Vs Sabio

The Supreme Court dismissed the petition challenging the constitutionality of Republic Act No. 7675, which converted Mandaluyong into a Highly Urbanized City and divided it from San Juan. The court ruled that the act did not violate the one subject one bill rule, the limit on the number of representatives, or the requirement for a census to establish separate legislative districts. The petitioners' claims were deemed without merit, and the law was presumed to have followed proper legislative processes.

Uploaded by

Love-Love Jeraldine Mondia Dalupines
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Tobias vs Abalos, G.R. No.

L-114783 case brief summary

December 8, 1994

Facts: Complainants, invoking their right as taxpayers and as residents of Mandaluyong, filed a
petition questioning the constitutionality of Republic Act No. 7675, otherwise known as "An Act
Converting the Municipality of Mandaluyong into a Highly Urbanized City to be known as the
City of Mandaluyong." Before the enactment of the law, Mandaluyong and San Juan belonged to
the same legislative district.

The petitioners contended that the act is unconstitutional for violation of three provisions of the
constitution. First, it violates the one subject one bill rule. The bill provides for the conversion of
Mandaluyong to HUC as well as the division of congressional district of San Juan and
Mandaluyong into two separate district. Second, it also violate Section 5 of Article VI of the
Constitution, which provides that the House of Representatives shall be composed of not more
than two hundred and fifty members, unless otherwise fixed by law. The division of San Juan
and Mandaluyong into separate congressional districts increased the members of the House of
Representative beyond that provided by the Constitution. Third, Section 5 of Article VI also
provides that within three years following the return of every census, the Congress shall make a
reapportionment of legislative districts based on the standard provided in Section 5. Petitioners
stated that the division was not made pursuant to any census showing that the minimum
population requirement was attained.

Issue:

(1) Does RA 7675 violate the one subject one bill rule?

(2) Does it violate Section 5(1) of Article VI of the Constitution on the limit of number of rep?

(3) Is the inexistence of mention of census in the law show a lack of constitutional requirement?

Rulings: The Supreme Court ruled that the contentions are devoid of merit. With regards to the
first contention of one subject one bill rule, the creation of a separate congressional district for
Mandaluyong is not a separate and distinct subject from its conversion into a HUC but is a
natural and logical consequence. In addition, a liberal construction of the "one title-one subject"
rule has been invariably adopted by this court so as not to cripple or impede legislation.

The second contention that the law violates the present limit of the number of representatives, the
provision of the section itself show that the 250 limit is not absolute. The Constitution clearly
provides that the House of Representatives shall be composed of not more than 250 members,
"unless otherwise provided by law”. Therefore, the increase in congressional representation
mandated by R.A. No. 7675 is not unconstitutional.

With regards, to the third contention that there is no mention in the assailed law of any census to
show that Mandaluyong and San Juan had each attained the minimum requirement of 250,000
inhabitants to justify their separation into two legislative districts, unless otherwise proved that
the requirements were not met, the said Act enjoys the presumption of having passed through the
regular congressional processes, including due consideration by the members of Congress of the
minimum requirements for the establishment of separate legislative district

The petition was dismissed for lack of merit.

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