G.R. No. 188179 ; January 22, 2013
HENRY R. GIRON, Petitioner, vs. COMMISSION ON ELECTIONS, Respondent, ALMARIO E. FRANCISCO, FEDERICO S. JONG JR., and RICARDO L. BAES JR., Petitioners-in-Intervention.

FACTS

Petitioner Henry R. Giron filed a special civil action for certiorari and prohibition assailing the constitutionality of Sections 12 (Substitution of Candidates) and 14 (Repealing Clause) of Republic Act No. 9006 , the Fair Election Act. The petition sought to prohibit the COMELEC from implementing these provisions, arguing they enable elective officials to gain a campaign advantage by allowing them to disburse public funds from the time they file their certificates of candidacy. The petitioners-in-intervention joined, reiterating Giron’s arguments.
Giron specifically contended that the inclusion of these sections violated the “one subject-one title” rule under Section 26(1), Article VI of the 1987 Constitution . He asserted that Sections 12 and 14 were unrelated to the Act’s main subject of lifting the political advertisement ban. Section 14 repealed Section 67 of the Omnibus Election Code, which mandated the ipso facto resignation of elective officials running for a different office. The COMELEC, through then-Chairperson Jose Melo, opposed, citing the Court’s prior ruling in Fariñas v. Executive Secretary which had already addressed the issue.

ISSUE

Whether or not the inclusion of Sections 12 and 14 in the Fair Election Act violates Section 26(1), Article VI of the 1987 Constitution , or the “one subject-one title” rule.

RULING

The Supreme Court dismissed the petition, upholding the constitutionality of the assailed provisions. The Court emphasized the strong presumption of constitutionality in favor of legislation. The burden lies on the challenger to prove a clear and unequivocal breach of the Constitution, which the petitioners failed to do. The Court found no compelling reason to reverse its established ruling in Fariñas v. Executive Secretary.
The legal logic rests on a reasonable, not technical, construction of the constitutional requirement. The title of R.A. 9006, “An Act to Enhance the Holding of Free, Orderly, Honest, Peaceful and Credible Elections through Fair Election Practices,” is comprehensive enough to reasonably include the general object of the statute. The repeal of Section 67 of the Omnibus Election Code and the rules on substitution of candidates are germane to this broad objective of enhancing fair and credible elections. To require every specific detail, like the repeal of a particular provision, to be expressed in the title would be to demand a complete index of the law’s contents, which is not what the Constitution requires. The Court concluded that the title encompasses the measures in the challenged sections, and thus, there was no violation of the one subject-one title rule.