FACTS:

The petitioners filed two separate petitions challenging the constitutionality of Section 14 of Republic Act No. 9006 (The Fair Election Act). They argue that this section, which repeals Section 67 of the Omnibus Election Code, violates the constitutional requirement of every law having only one subject expressed in its title. The petitioners are members of the minority bloc in the House of Representatives, and one of them is also a member of the House. The respondents named in the petitions include the Executive Secretary, Speaker of the House of Representatives, Commission on Elections, Department of the Interior and Local Government, Senate, and House of Representatives.

In the legislative history of Republic Act No. 9006, the bill underwent consolidation from two bills originating from the House and Senate, followed by the reconciliation of conflicting provisions through a Bicameral Conference Committee. The House proposed an amendment to the Committee Report, leading to a second election of conferees and submission of a new report. Both the House and Senate approved the new Bicameral Conference Committee Report, and the President then signed the bill into law. The petitioners question the constitutionality of Section 14 due to its inclusion and repeal of Section 67 of the Omnibus Election Code.

The case primarily revolves around the constitutionality of Section 14 of Republic Act No. 9006. The petitioners argue that this section, which repeals Section 67 of the Omnibus Election Code, is a proscribed rider and violates the equal protection clause. They maintain that the repeal of Section 67 is unrelated to the subject matter of Republic Act No. 9006, which focuses on the use of media for election propaganda and unfair election practices. The petitioners also contend that the repeal discriminates against appointive officials since it retains Section 66, which imposes a similar limitation on them. They further claim that the entire Republic Act No. 9006 is null and void due to irregularities in its enactment, and that Section 67 of the Omnibus Election Code is a valid law and should not have been repealed.

On the other hand, the respondents argue that the petitioners lack legal standing to file the suit and that the enrolled bill doctrine applies, deeming the bill, including Section 14, as duly enacted into law. They assert that the repeal of Section 67 is relevant to the subject matter of Republic Act No. 9006 as expressed in its title. They also argue that such repeal eliminates the unfairness of considering elective officials automatically resigned upon filing their certificate of candidacy for a different elective office.

In addition to the constitutional issues, the respondents argue that Section 16 of Republic Act No. 9006, which provides for penalties for violations, does not violate the due process clause as it assumes compliance with the formalities of the law. They further contend that the Speaker and Secretary General of the House of Representatives did not commit grave abuse of discretion in not excluding members who ran for the Senate during the 2001 elections, as they were simply following the provisions of Republic Act No. 9006.

ISSUES:

1. Whether Section 14 of Republic Act No. 9006, repealing Section 67 of the Omnibus Election Code, is unconstitutional for violating the "one subject, one title" rule prescribed by Section 26(1), Article VI of the Constitution.

2. Whether the repeal of Section 67 of the Omnibus Election Code, which pertains to elective officials, by Section 14 of RA 9006 without repealing Section 66 of the Election Code, which pertains to appointive officials, violates the equal protection clause of the Constitution.

3. Whether the entire Republic Act No. 9006 is null and void due to alleged irregularities in its enactment.

4. Whether Section 16 of Republic Act No. 9006, which specifies that the Act shall take effect immediately upon its approval, is a violation of the due process requirement for publication prior to effectivity.

RULING:

1. One subject-one title rule The Court ruled that Section 14 of Republic Act No. 9006 is not a proscribed rider and does not violate the "one subject-one title" rule. The title of RA 9006 is comprehensive enough to include the repeal of Section 67 of the Omnibus Election Code within its contemplation. To require the title to be a complete index of its content was not necessary.

2. Equal protection clause The Court held that Section 14 of RA 9006 does not violate the equal protection clause of the Constitution. Substantial distinctions exist between elective and appointive officials, justifying different treatment under the law.

3. Validity of the entire Act The Court dismissed the claim that the entire RA 9006 should be nullified due to irregularities during its enactment. The "enrolled bill" doctrine was applied, wherein the signatures of the legislative leaders and the certification by legislative secretaries serve as conclusive evidence of a bill’s due enactment.

4. Effectivity clause The Court found Section 16, specifying immediate effectivity upon approval, to be defective since it conflicts with the requirement for publication. However, this did not render the entire Act invalid. Instead, the Act would take effect 15 days after its publication in the Official Gazette or a newspaper of general circulation.

PRINCIPLES:

1. One subject-one title rule Titles of statutes should be broad enough to include various provisions related to the general object of the statute

2. Equal protection clause Reasonable classification based on substantial distinctions justifies different treatment under the law.

3. Enrolled bill doctrine The signed and certified bill is conclusive evidence of due enactment.

4. Publication requirement All laws must be published before becoming effective, regardless of specified immediate effectivity.