G.R. No. L-114783, December 8, 1994
Robert V. Tobias, et al. vs. Hon. City Mayor Benjamin S. Abalos, et al.

FACTS

Petitioners, as taxpayers and residents of Mandaluyong, assail the constitutionality of Republic Act No. 7675 , which converted the Municipality of Mandaluyong into a highly urbanized city. The law, signed on February 9, 1994, was ratified in a plebiscite on April 10, 1994, where only Mandaluyong residents participated. Its Section 49 provides that as a highly urbanized city, Mandaluyong shall have its own legislative district, with the remainder of the former San Juan/Mandaluyong district becoming the new district of San Juan.
Petitioners contend Section 49 violates the Constitution on three grounds. First, it breaches the “one subject-one bill” rule under Article VI, Section 26(1), as the law’s title addresses only Mandaluyong’s conversion, yet Section 49 deals with congressional reapportionment. Second, it contravenes Article VI, Section 5(1) by increasing House membership beyond 250 without a legal basis. Third, it violates Section 5(4) by preempting Congress’ power to reapportion districts based on a census.

ISSUE

Whether Republic Act No. 7675 , particularly Section 49, is unconstitutional.

RULING

The Supreme Court dismissed the petition, upholding the constitutionality of R.A. No. 7675 . On the first issue, the Court ruled that the creation of a separate congressional district for Mandaluyong is not a distinct subject but a natural and logical consequence of its conversion into a highly urbanized city. The constitutional mandate under Article VI, Section 5(3) requires a city with a population of at least 250,000 to have at least one representative. Thus, the subject of Section 49 is germane to the law’s general subject. The Court applied a liberal, practical construction of the “one title-one subject” rule, as established in Sumulong v. Comelec and Lidasan v. Comelec.
Regarding the second issue, the Court found that the 250-member limit in Article VI, Section 5(1) is not absolute, as it includes the clause “unless otherwise fixed by law.” The increase in representation mandated by R.A. No. 7675 is therefore a valid exercise of legislative power. On the third issue, the argument that Congress preempted itself is untenable, as Congress itself enacted the law. The ancillary matter of district division did not require San Juan’s participation in the plebiscite, and no evidence of gerrymandering was substantiated, especially since the author, Rep. Zamora, diminished his own constituency. The law stands as constitutional.