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Updated 25th February 2025
Giron vs. Commission on Elections
Henry Giron challenged the constitutionality of Sections 12 and 14 of Republic Act No. 9006 (Fair Election Act), which deal with substitution of candidates and repeal of certain provisions of the Omnibus Election Code, claiming they violate the "one subject-one title" rule of the Constitution.

Primary Holding

The Supreme Court upheld the constitutionality of Sections 12 and 14 of RA 9006, finding that they are germane to the general subject of the law, which aims to ensure fair election practices.

Background

The case was a special civil action for certiorari and prohibition filed by Giron against the Commission on Elections (COMELEC) regarding the implementation of the Fair Election Act.

History

  • Petition filed on January 22, 2013.

  • Previous case, Fariñas v. Executive Secretary, was referenced where similar issues were addressed.

Facts

  • 1. Henry R. Giron filed a petition against Sections 12 and 14 of RA 9006, asserting these sections violate the Constitution's one subject-one title rule by not being related to the main subject of lifting the political ad ban.

Arguments of the Petitioners

  • 1. Sections 12 and 14 of RA 9006 are unrelated to the main subject of the Fair Election Act, thus violating the "one subject-one title" rule under the Constitution.

Arguments of the Respondents

  • 1. The title and objectives of RA 9006 are comprehensive enough to include the issues of substitution of candidates and the repeal of certain provisions of the election laws. Reference was made to the Fariñas case for precedent.

Issues

  • 1. Whether the inclusion of Sections 12 and 14 in RA 9006 violates Section 26(1), Article VI of the 1987 Constitution.

Ruling

  • 1. The Supreme Court ruled that Sections 12 and 14 are within the contemplation of the Fair Election Act's title, which seeks to promote fair election practices. The Court found no clear breach of the Constitution by Congress.

Doctrines

  • 1. Doctrine of Reasonable Construction: Statutes should be interpreted in light of the purpose for which they were passed, with the title being comprehensive enough to include related provisions.
  • 2. Strong Presumption of Validity: Laws are presumed constitutional, and the burden lies on the one challenging it to prove otherwise.

Precedents Cited

  • 1. "Constitutional provisions relating to the subject matter and titles of statutes should not be so narrowly construed as to cripple or impede the power of legislation."

Statutory and Constitutional Provisions

  • 1. Section 26(1), Article VI of the 1987 Constitution: Relating to the "one subject-one title" rule.
  • 2. Section 12 (Substitution of Candidates) and Section 14 (Repealing Clause) of Republic Act No. 9006.