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ROBERT V. TOBIAS v. CITY MAYOR BENJAMIN S. ABALOS

FACTS:

The case involves the constitutionality of Republic Act No. 7675, which converts the Municipality of Mandaluyong into a highly urbanized city. Prior to the enactment of the law, Mandaluyong and San Juan belonged to the same legislative district. The incumbent congressional representative of the district sponsored the bill that became RA 7675.

A plebiscite was held, in which the people of Mandaluyong approved the conversion into a highly urbanized city. The petitioners in this case are taxpayers and residents of Mandaluyong who argue that Section 49 of RA 7675 is unconstitutional. They claim that it violates the "one subject-one bill" rule and the provisions of the Constitution regarding the composition of the House of Representatives and the reapportionment of legislative districts.

The court, however, finds the petitioners’ contentions to be without merit.

ISSUES:

  1. Whether Article VIII, Section 49 of Republic Act No. 7675 violates the "one subject-one bill" rule as enunciated in Article VI, Section 26 (1) of the Constitution.

  2. Whether the division of San Juan and Mandaluyong into separate congressional districts under Section 49 of Republic Act No. 7675 increases the composition of the House of Representatives beyond that provided in Article VI, Section 5 (1) of the Constitution.

  3. Whether the division of San Juan and Mandaluyong into separate congressional districts under Section 49 of Republic Act No. 7675 preempted the right of Congress to reapportion legislative districts pursuant to Article VI, Section 5 (4) of the Constitution.

RULING:

  1. The Court held that the contentions of the petitioners are devoid of merit.

PRINCIPLES:

  • "One subject-one bill" rule - Every bill passed by Congress must embrace only one subject which shall be expressed in the title thereof, as provided in Article VI, Section 26 (1) of the Constitution.

  • "One city-one representative" proviso - Each city with a population of not less than two hundred fifty thousand is entitled to have one representative in the House of Representatives as provided in the Constitution.