ROBERT V. TOBIAS, ET AL. vs. BENJAMIN S. ABALOS, ET AL.

Facts:
Mandaluyong and San Juan were one legislative district until the passage of the
RA 7675 with title An Act Converting the Municipality of Mandaluyong into a
Highly Urbanized City to be known as the City of Mandaluyong." Same bill is now
in question at to its constitutionality by the petitioners by invoking their right as
tax payers and residents of Mandaluyong.
With a plebiscite held on April 10, 1994, people of Mandaluyong voted to for the
the conversion of Mandaluyong to a highly urbanized city ratifying RA 7675 and
making it in effect.
Issues:
WON RA 7675 is in:
1. Violation of Article VI, Section 26(1) of the Constitution regarding 'one subject
one bill rule".
2. Violation of Article VI, Sections 5(1) and (4) as to the number of members of
the Congress to 250 and reappropriating the legislative districts.
Ruling:
Applying liberal construction the Supreme Court dismissed the contention of
constitutionality pertaining to Art VI 26(1) saying "should be given a practical
rather than a technical construction. It should be sufficient compliance with such
requirement if the title expresses the general subject and all the provisions are
germane to that general subject."
As to Article VI Sec 5(1), the clause "unless otherwise provided by law" was
enforced justifying the act of the legislature to increase the number of the
members of the congress.
Article VI Sec 5 (4) was also overruled as it was the Congress itself which drafted
the bill reapportioning the legislative district.
In view of the foregoing facts, the petition was dismissed for lack of merit.