Tañada vs. Tuvera (G.R. No.

L-63915, April 24, 1985)

Facts: Petitioners, citing the people’s right to be informed under Section 6, Article IV of the 1973
Constitution, sought a writ of mandamus to compel the respondents to perform their public duty
of publishing and/or causing the publication of presidential issuances in the Official Gazette, in
accordance with the principle that laws must be published in the Official Gazette or otherwise
effectively promulgated to be valid and enforceable. The respondents, through the Solicitor
General, contended that the petitioners do not have the legal standing to file the petition, as they
are neither personally nor directly impacted by the claimed failure to publish the presidential
issuances in question, and called for the petition's immediate dismissal. Petitioners argue that, as
the petition addresses a public right and seeks to enforce a public duty, no specific personal
interest is needed for it to proceed. Furthermore, respondents argue that publication in the
Official Gazette is not necessary for the effectivity of laws that specify their own effective dates.
They contend that since the presidential issuances include such provisions, publication is not
required for them to take effect.

Issue:
1. Whether or not the petitioners have legal standing to institute a mandamus proceeding
compelling respondents to cause the publication of various presidential issuances in the
Official Gazette.
2. Whether or not publication in the Official Gazette is a requirement for the effectivity of
the presidential issuances, regardless of the laws specifying their own effectivity dates.

Ruling:
1. The Court acknowledges that petitioners have legal standing. The issue involves public
right, specifically the people’s constitutional right to be informed on matters of public
concern, as recognized by the 1973 Philippine Constitution. Since the petition aims to
enforce a public duty, petitioners, as citizens interested in the execution of the laws, need
not demonstrate any specific interest. This aligns with precedents such as Severino vs.
Governor General, where the Court allowed private individuals to bring a case when a
public right is at stake.
2. The Court ruled that the publication is a requirement for the effectivity of the presidential
issuances. While some presidential issuances contain provisions specifying their own
effectivity dates, publication in the Official Gazette is still required for those of general
applicability, as mandated by Section 1 of Commonwealth Act 638. This is consistent
with the Court’s interpretation that even when an issuance specifies its own effectivity,
publication remains necessary for transparency and to ensure that the public is properly
informed, fulfilling the constitutional right to be informed on matters of public concern.

Umali vs. Estanislao (G.R. No. 104037, May 29, 1992)

Facts: Republic Act No. 7167, enacted on December 19, 1991, increased the basic personal and
additional exemptions for income tax, with the law taking effect after its publication on January
14, 1992. However, the respondents issued Revenue Regulations No. 1-92 on December 26,
1992, which postponed its implementation until January 1, 1992. In response, two petitions were
filed, seeking to compel the respondents to apply the law to taxable income for 1991 and to block
the implementation of the regulations. The Court consolidated the cases on March 10, 1992.

Issue:
1. Whether or not RA No. 7167 took effect on December 19, 1991, upon presidential
approval, or on January 30, 1992, after its publication on January 14, 1992.
2. Whether or not the said law applies to compensation income earned or received in 1991.

Ruling:
1. The Court decided that Republic Act No. 7167 became effective on January 30, 1992,
after its publication in the "Malaya" newspaper on January 14, 1992, in accordance with
Article 2 of the Civil Code. Although the law was signed by the President on December
19, 1991, it did not specify an immediate effect upon approval, thus necessitating the 15-
day publication period. Citing the Caltex (Phils.), Inc. vs. The Commissioner of Internal
Revenue case, the Supreme Court affirmed that laws take effect 15 days after publication
unless stated otherwise. As a result, the law took effect on January 30, 1992, after the
required publication period.
2. The Court ruled that RA No. 7167 applies to compensation income earned in 1991, as its
purpose was to adjust exemptions to alleviate the effects of inflation and the rising cost of
living. While the law became effective on January 30, 1992, its provisions for increased
exemptions were meant to apply retroactively to 1991. Despite the Commissioner of
Internal Revenue's attempt to delay implementation through Revenue Regulations No. 1-
92, which applied the exemptions to 1992 income, the Court held that the law's intent was
to ease the tax burden for 1991 income. As a result, taxpayers who filed without the
increased exemptions were entitled to refunds or credits.

Fariñas vs. Executive Secretary (G.R. No. 147387, December 10, 2003)

Facts: The case involves two petitions filed in the Supreme Court. The petitioners sought to
declare the unconstitutionality of Section 14 of RA No. 9006, as it repeals Section 67 of the
Omnibus Election Code and thus constitutes a proscribed rider. They argue that the repeal of
Section 67 of the Omnibus Election Code is neither included in the title nor relevant to the
subject of RA No. 9006. Moreover, petitioners contend that Section 14 of RA No. 9006
discriminates against appointive officials as Section 66 of the Omnibus Election Code, which
imposes a similar limitation to appointive officials, remain and thus violates the equal protection
clause of the Constitution because it repeals Section 67 only. Furthermore, petitioners contend
that RA No. 9006 is null and void in its entirety because of the irregularities surrounding its
enactment, including Section 16 of the RA No. 9006 which states that its effectivity will take
effect upon its approval, a violation of the due process clause of the Constitution and of
jurisprudence, which require publication of the law before it becomes effective.

Respondents, through the Solicitor General, sought the dismissal of the petitions asserting that
the petitioners have no legal standing to institute the present suit. The respondents further
contend that Section 14 of RA No. 9006 is not a proscribed rider, as the Act’s broad title covers
all election processes, including filing candidacy certificates. Denying the alleged violation of
the equal protection clause, the respondents assert that a substantial distinction exists between
elective officials and appointive officials and that they cannot be similarly treated as the same as
the former occupy their office based upon popular will while the latter is not elected by the
populace. Lastly, Invoking the enrolled bill doctrine, the respondents dismissed claims of
irregularities in the enactment of RA No. 9006, asserting that the signatures of the Senate
President, House Speaker, and respective Secretaries serve as definitive proof of the law's proper
passage.

Issues:
1. Whether or not Section 14 of RA No. 9006 is unconstitutional for violating the one-
subject rule outlined in the 1987 Constitution.
2. Whether or not the repeal of Section 67 of the Omnibus Election Code violates the equal
protection clause.
3. Whether or not irregularities occurred during the enactment of RA No. 9006.
4. Whether or not the effectivity clause of RA No. 9006 is valid.

Ruling:
1. The Court decided that Section 14 of Republic Act No. 9006 is not unconstitutional and
does not break the one-subject rule. The Court explained that the law's title, which
focuses on improving free and fair elections, is broad enough to include the repeal of
Section 67 of the Omnibus Election Code. It stated that a law's title should reasonably
reflect its purpose, allowing provisions that support the overall goal of the law. The Court
also pointed out that removing Section 67 was related to the law's goal of promoting fair
elections.
2. The Court ruled that repealing Section 67 does not go against the equal protection clause
of the Constitution. It explained that there are important differences between elected and
appointed officials, which justifies treating them differently under the law. The Court
added that the equal protection clause does not stop reasonable classifications based on
these real differences.
3. The Court determined that there were no significant irregularities in the creation of
Republic Act No. 9006 that would make the law invalid. It followed the enrolled bill
doctrine, which assumes that a bill signed by legislative leaders and certified by the
secretaries of both houses was properly passed. The Court concluded that any claimed
irregularities were minor procedural issues and did not violate the Constitution.
4. The Court found that the effectivity clause was flawed but did not make the entire law
invalid. Although the clause stated that the law would take effect immediately upon
approval, the Court ruled that it would still take effect 15 days after publication, as per
standard legal rules.

La Bugal-B’laan Tribal Association, Inc. vs. Ramos (G.R. No. 127882, December 1, 2004)

Facts: The case of La Bugal-B'laan Tribal Association, Inc. v. Ramos focuses on the
constitutionality of Republic Act No. 7942, known as the Philippine Mining Act of 1995, its
Implementing Rules (DENR Administrative Order No. 96-40), and a Financial and Technical
Assistance Agreement (FTAA) dated March 30, 1995, between the Philippine government and
Western Mining Corporation (Philippines), Inc. (WMCP). The petitioners, led by the La Bugal-
B'laan Tribal Association, Inc., represented by Chairman F'long Miguel M. Lumayong, argued
that these legal measures violated Section 2, Article XII of the 1987 Constitution, which requires
that the exploration, development, and use of natural resources be fully controlled by the State.
Initially, the Supreme Court ruled on January 27, 2004, that certain parts of RA 7942, DAO 96-
40, and the FTAA were unconstitutional. However, after the respondents filed motions for
reconsideration, further discussions led to a new resolution on December 1, 2004.

Issues:
1. Whether or not the case has been rendered moot by the sale of WMC shares in WMCP to
Sagittarius, a Filipino-owned corporation.
2. Whether or not it would still be proper to resolve the constitutionality of the challenged
provisions of the Mining Law, DAO 96-40, and the WMCP FTAA, assuming the case has
been rendered moot.
3. Whether or not the proper interpretation of the phrase “Agreements Involving Either
Technical or Financial Assistance” in paragraph 4 of Section 2 of Article XII of the
Constitution has been established.

Ruling:
The Supreme Court granted the respondents’ and intervenors’ motions for reconsideration,
overturning its earlier decision from January 27, 2004.
1. The Court ruled that the sale of WMC shares to a Filipino-owned corporation made the
foreign ownership issue moot, as the FTAA would not be managed by a qualified Filipino
corporation. The Court further explained that the Constitution should foster economic
growth and attract foreign investments, while ensuring that the State retains control over
natural resources.
2. The Court upheld the constitutionality of RA No. 7942 (Philippine Mining Law) and its
IRR (DOA 96-40) in relation to financial and technical assistance. It also affirmed the
FTAA dated March 30, 1995, except for Sections 7.8 and 7.9, which were invalidated for
being contrary to public policy and harmful to the government’s interests.
3. The Court interpreted the phrase “agreements involving either technical or financial
assistance” in Section 2, Article XII of the 1987 Constitution to include service contracts,
allowing foreign corporations to offer comprehensive services, including management,
for the exploration, development, and utilization of mineral resources. However, it
stressed that the State must maintain full control and supervision over these activities,
similar to a board of directors overseeing a corporation.

Lidasan vs. COMELEC (G.R. No. L-28089, October 25, 1967)

Facts: Bara Lidasan, a resident, voter, and taxpayer of Parang, Cotabato, challenged the
constitutionality of RA No. 4790, which aims to create the Municipality of Dianaton in the
Province of Lanao del Sur. The Act included barrios that were in the Province of Cotabato,
specifically from the municipalities of Buldon and Parang. The COMELEC decided to
implement the Act for electoral purposes, despite including barrios from another province. This
led Lidasan to seek a writ of certiorari and prohibition, arguing the Act violated the constitutional
requirement that a bill must cover only one subject, clearly stated in its title. The case was
brought to the Supreme Court after COMELEC refused to suspend the Act, despite the
President’s recommendation for corrective legislation.
Issue:
1. Whether or not RA No. 4790 violated the constitutional requirement that no bill shall
embrace more than one subject, which must be expressed in the title of the bill.
2. Whether or not the petitioner has the standing to challenge the constitutionality of RA
No. 4790.

Ruling:
1. The Supreme Court ruled that RA No. 4790 is null and void for violating the
constitutional requirement that a bill's title must reflect its single subject. The Court found
the title misleading, as it only mentioned the creation of the Municipality of Dianaton in
Lanao del Sur, without indicating that it also involved transferring barrios from Cotabato,
affecting the boundaries of two provinces. The Court emphasized that such a significant
aspect must be disclosed in the title. It also rejected the argument that the transfer of
barrios was incidental, stating that it was integral to the Act, making the entire law
unconstitutional.
2. The Court ruled that petitioner Bara Lidasan had the standing to challenge the Act's
constitutionality, as his rights as a voter and taxpayer were impacted. It acknowledged
that, being a qualified voter and taxpayer in the affected area, Lidasan had a valid interest
in ensuring the law governing his electoral rights was constitutional, thus granting him
the right to challenge the Act.