TOBIAS v ABALOS, G.R. No.

L-114783, December 8, 1994

Facts:

Complainants, invoking their right as taxpayers and as residents of Mandaluyong, filed a petition
questioning the constitutionality of Republic Act No. 7675, otherwise known as "An Act Converting the
Municipality of Mandaluyong into a Highly Urbanized City to be known as the City of Mandaluyong."
Before the enactment of the law, Mandaluyong and San Juan belonged to the same legislative district.

The petitioners contended that the act is unconstitutional for violation of three provisions of the
constitution. First, it violates the one subject one bill rule as enunciated in Sec. 26(1), Article VI of the
Constitution. The bill provides for the conversion of Mandaluyong to HUC as well as the division of
congressional district of San Juan and Mandaluyong into two separate district. Second, it also violates Sec.
5, Article VI of the Constitution, which provides that the House of Representatives shall be composed of
not more than two hundred and fifty members, unless otherwise fixed by law. The division of San Juan
and Mandaluyong into separate congressional districts increased the members of the House of
Representative beyond that provided by the Constitution. Third, Sec. 5, Article V of the ConstitutionI also
provides that within three years following the return of every census, the Congress shall make a
reapportionment of legislative districts based on the standard provided in Section 5. Petitioners stated
that the division was not made pursuant to any census showing that the minimum population
requirement was attained.

Issues:

1. Does R.A. 7675 violate the one subject one bill rule?
2. Does it violate Section 5(1) of Article VI of the Constitution on the limit of number of
representative? [PRINCIPLE: REAPPORTIONMENT OF LEGISLATIVE DISTRICTS]
3. Is the inexistence of mention of census in the law show a lack of constitutional requirement?
[PRINCIPLE: Same in No. 2]

Rulings:

The Supreme Court ruled that the contentions are devoid of merit. With regards to the first
contention of one subject one bill rule, the creation of a separate congressional district for Mandaluyong
is not a separate and distinct subject from its conversion into a HUC but is a natural and logical
consequence. In addition, a liberal construction of the "one title-one subject" rule has been invariably
adopted by this court so as not to cripple or impede legislation.

The second contention that the law violates the present limit of the number of representatives,
the provision of the section itself show that the 250 limit is not absolute. The Constitution clearly provides
that the House of Representatives shall be composed of not more than 250 members, "unless otherwise
provided by law. Therefore, the increase in congressional representation mandated by R.A. No. 7675 is
not unconstitutional.

With regards to the third contention that there is no mention in the assailed law of any census to
show that Mandaluyong and San Juan had each attained the minimum requirement of 250,000
inhabitants to justify their separation into two legislative districts, unless otherwise proved that the
requirements were not met, the said Act enjoys the presumption of having passed through the regular
congressional processes, including due consideration by the members of Congress of the minimum
requirements for the establishment of separate legislative district

The petition was dismissed for lack of merit.