GR 129118; (July, 2000) (Digest)
G.R. No. 129118; July 19, 2000
AGRIPINO A. DE GUZMAN, JR., ET AL., petitioners, vs. COMMISSION ON ELECTIONS, respondent.
FACTS
The petitioners, a large group of COMELEC Election Officers, filed a petition for certiorari and prohibition challenging the constitutionality of Section 44 of Republic Act No. 8189, “The Voter’s Registration Act of 1996.” This provision mandates the reassignment of election officers who have served in a particular city or municipality for more than four years. The petitioners argued that this section was an invalid rider, as it was allegedly not germane to the subject matter expressed in the title of the law, which pertains to voter registration.
They contended that the inclusion of this reassignment provision violated Section 26(1), Article VI of the 1987 Constitution, which requires that every bill must embrace only one subject which shall be expressed in its title. The petitioners asserted that the provision on the reassignment of COMELEC personnel was a distinct and unrelated subject, improperly attached to a law primarily concerned with registration procedures and systems.
ISSUE
Whether or not Section 44 of R.A. No. 8189 is unconstitutional for allegedly violating the “one title-one subject” rule under Section 26(1), Article VI of the 1987 Constitution.
RULING
The Supreme Court upheld the constitutionality of Section 44 and dismissed the petition. The Court ruled that the provision is not an invalid rider but is germane to the law’s principal subject of voter registration. The constitutional requirement does not demand that the title be a complete index of the law’s contents; it is sufficient that the title expresses the general subject and that all provisions are related to it.
The legal logic is that Section 44, which provides for the periodic reassignment of election officers, is directly relevant to ensuring the integrity and credibility of the continuing registration process mandated by R.A. No. 8189. By preventing election officers from becoming too familiar with local political conditions, the reassignment rule is a preventive measure against potential fraud and partiality, thereby protecting the sanctity of the voter’s list. Since the provision is related and auxiliary to the main objective of securing an honest and accurate system of continuing registration, it does not violate the one-title-one-subject rule. The Court found no grave abuse of discretion in its enactment and accorded the usual presumption of constitutionality to the legislative act.