Mariano versus Comelec Constitutional

Summary:

The petitioners, as taxpayers and residents of Mandaluyong, challenged the constitutionality of Republic Act Number seventy-seven thousand six hundred seventy-five, which converted the Municipality of Mandaluyong into a highly urbanized city. They specifically contested Article eight, Section forty-nine of the Act, which created separate legislative districts for Mandaluyong and San Juan.

The petitioners argued that this provision violated the "one-subject-one bill" rule, exceeded the constitutional limit on the number of representatives, and preempted Congress' right to reapportion legislative districts. The Supreme Court dismissed the petition, ruling that R.A. Number seventy-seven thousand six hundred seventy-five was constitutional.

Doctrine:

"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. Thus, in Sumulong versus Comelec, we ruled that the constitutional requirement as now expressed in Article six, Section twenty-six should be given a practical rather than a technical construction. It should be sufficient compliance with such requirement if the title expresses the general subject and all the provisions are germane to that general subject."

"The Constitution clearly provides that the House of Representatives shall be composed of not more than two hundred fifty members, unless otherwise provided by law. The inescapable import of the latter clause is that the present composition of Congress may be increased, if Congress itself so mandates through a legislative enactment."

Fourteen thousand eight hundred twenty-one voted "yes" while seven thousand nine hundred eleven voted "no" in the plebiscite.

Article eight, Section forty-nine of R.A. Number seventy-seven thousand six hundred seventy-five created separate legislative districts for Mandaluyong and San Juan.

Petitioners challenged the constitutionality of R.A. Number seventy-seven thousand six hundred seventy-five, particularly Section forty-nine.