G.R. No. 147387 and G.R. No. 152161; December 10, 2003
RODOLFO C. FARIÑAS, ET AL., petitioners, vs. THE EXECUTIVE SECRETARY, ET AL., respondents; and GERRY A. SALAPUDDIN, petitioner, vs. COMMISSION ON ELECTIONS, respondent.

FACTS

Petitioners, members of the House of Representatives, assail the constitutionality of Section 14 of Republic Act No. 9006 (The Fair Election Act). This provision expressly repealed Section 67 of the Omnibus Election Code (BP 881), which deemed an elective official as ipso facto resigned upon filing a certificate of candidacy for any office other than the one currently held. The petitioners argue that the inclusion of this repealing clause in RA 9006 constitutes a proscribed rider, violating the constitutional requirement under Article VI, Section 26(1) that every bill must embrace only one subject expressed in its title. They contend that the repeal of the resignation rule is unrelated to the law’s primary subject of enhancing election practices through media use and other campaign reforms.
The legislative history reveals that the repeal of Section 67 was inserted during the bicameral conference committee proceedings. The petitioners highlight that the original House and Senate bills focused on election propaganda and fair practices, with no mention of repealing the resignation rule for elective officials. They assert that this insertion, which substantially alters the legal status of incumbent officials running for office, is not germane to the act’s expressed purpose of regulating election propaganda and practices, thereby making it an unconstitutional rider.

ISSUE

Whether Section 14 of RA 9006, insofar as it repeals Section 67 of BP 881, is unconstitutional for being a rider that violates the “one title-one subject” rule of the Constitution.

RULING

The Supreme Court DISMISSED the petitions and declared Section 14 of RA 9006 CONSTITUTIONAL. The Court held that the repeal of Section 67 is not a rider. The constitutional requirement is satisfied if the title of the law is comprehensive enough to include the general purpose of the act and all its provisions. RA 9006 is entitled “An Act to Enhance the Holding of Free, Orderly, Honest, Peaceful and Credible Elections through Fair Election Practices.” The Court ruled that the repeal of the automatic resignation rule is germane to this overarching objective. The rationale is that the repealed provision was perceived as coercive, potentially limiting the freedom of choice of both the official and the electorate. Its removal is considered a “fair election practice” aimed at leveling the electoral playing field and is directly related to achieving credible elections. The Court further explained that the title of RA 9006 is broad enough to encompass provisions affecting the candidacy of elective officials, as such matters are integral to the conduct of free and credible elections. Therefore, the repealing clause is not extraneous but is in harmony with the law’s general subject.