Primary Holding

RA 4790 is void for violating the Single Subject Rule under Article VI, Section 21(1) of the 1935 Constitution.

Background

RA 4790 aimed to create Dianaton from barrios in Lanao del Sur and Cotabato. The Office of the President urged suspending its implementation, but COMELEC enforced it. Petitioner Bara Lidasan, a Cotabato resident, challenged the law’s validity.

Facts

• 1. RA 4790 aimed to create the Municipality of Dianaton by combining 21 barrios: 9 from Lanao del Sur and 12 from Cotabato (specifically from Buldon and Parang municipalities in Cotabato).
• 2. The law’s title stated it would create Dianaton "in the Province of Lanao del Sur," but omitted any mention of Cotabato barrios.
• 3. The inclusion of Cotabato barrios effectively transferred territory between provinces, altering Lanao del Sur’s and Cotabato’s boundaries.
• 4. Legislators and the public were misled by the title, as Cotabato barrios’ transfer was a substantive change not reflected in the law’s heading.
• 5. Petitioner Bara Lidasan, a Cotabato resident, contested the law for depriving his municipality of territory without proper constitutional notice.

Arguments of the Petitioners

• 1. The title misled legislators and the public by failing to disclose the transfer of Cotabato barrios. This violated the constitutional mandate that the law’s subject must be expressed in its title.

Arguments of the Respondents

• 1. COMELEC argued boundary changes were incidental to creating Dianaton. Cited Felwa v. Salas to claim the title’s sufficiency if the main subject (municipality creation) was clear.

Issues

• 1. Whether RA 4790 violated the Single Subject Rule by failing to express its full scope (transfer of Cotabato barrios) in the title.

Ruling

• 1. The Court nullified RA 4790. The title’s omission of Cotabato barrios was misleading, violating constitutional notice requirements. The law was deemed indivisible, as Congress intended the 21 barrios as a cohesive unit.

Doctrines

• 1. Single Subject Rule: Laws must have one subject expressed in the title.
• 2. Separability Doctrine: Invalid parts may be severed unless the law’s purpose depends on them.
• 3. Voter Standing: Affected citizens may challenge laws impairing residency/voting rights.

Key Excerpts

• 1. “The phrase ‘in the Province of Lanao del Sur’ [...] makes the title misleading.”
• 2. “To do so [...] is to pass the line which circumscribes the judiciary and tread on legislative premises.”

Precedents Cited

• 1. Felwa v. Salas: Distinguished as inapplicable (creation of provinces vs. municipality).
• 2. Hume v. Village of Fruitport: Applied to invalidate misleading titles altering provincial boundaries.
• 3. Wilcox v. Paddock and Fuqua v. City of Mobile: Cited as examples of invalid boundary changes.

Statutory and Constitutional Provisions

• 1. 1935 Constitution, Art. VI, Sec. 21(1): Single Subject Rule.
• 2. 1935 Constitution, Art. VI, Sec. 18: Bills of local application originate in the House.