Tobias v. Abalos

PRINCIPLES:

• The creation of a separate congressional district is a natural and logical consequence of its conversion into a highly urbanized city.
• The present limit of 250 members in the HoR is not absolute as the present composition of the Congress may be increased through a legislative enactment.
• It is not required that all laws emanating from the legislature must contain all relevant data considered by the congress (e.g. census) in the enactment of said laws.

FACTS: 

Petitioners as taxpayers assail the constitutionality of RA 7675 converting the Municipality of Mandaluyong into a HUC. Prior to the enactment, the municipalities of Mandaluyong and San Juan belonged to only one legislative district. 

Petitioners argued that:

1. the law violated the “one subject-one bill” rule as it embraces 2 subjects: 1) conversion of Mandaluyong into a HUC; and 2) the division of the congressional district of San Juan and Mandaluyong into 2 separate districts. 
2. the division of the two districts resulted in the increase in the composition of the HoR contrary to Article 6, Sec. 5[1] of the Constitution
3. the division was not made pursuant to any census. 

ISSUES:

I) WON RA 7675 violated the “one subject-one bill” rule.

II) WON RA 7675 violated the present limit of 250 members in the HOR

III) WON the absence of the census as a basis in enacting the law rendered RA 7675 unconstitutional.

RULING:

I.

No, RA 7675 did not violate the “one subject-one bill” rule. 

The SC held that the creation of a separate congressional district for Mandaluyong is not a subject separate and distinct from the subject of its conversion into a highly urbanized city but is a natural and logical consequence of its conversion into a HUC. 

In this case, RA RA 7675 which is an act converting the Municipality of Mandaluyong into a HUC necessarily includes and contemplates the subject regarding the creation of a separate congressional district for Mandaluyong. 

Therefore the law did not violate the “one subject-one bill” rule. 

II.

No, RA 7675 did not violate Article 6, Sec. 5[1] of the Constitution.

Under the Constitution, the HoR shall be composed of not more than 250 members, unless otherwise provided by law. 

Hence, the present limit of 250 members is not absolute as the present composition of the Congress may be increased through a legislative enactment such as RA 7675.

Therefore, RA 7675 did not violate the present limit of 250 members in the HoR. 

III.

No, absence of showing the census as a basis in the enactment of the law does not render RA 7675 unconstitutional.

The SC held that the law enjoys the presumption of having passed through the regular congressional processes. It is not required that all laws emanating from the legislature must contain all relevant data considered by the congress in the enactment of said laws.