Republic Act No. 7854, particularly its sections 2 (territorial delineation), 51 (continuity of officials and new corporate existence), and 52 (creation of legislative districts), is constitutional. The delineation of territory by reference to existing boundaries is permissible, especially with pending boundary disputes. Challenges to term limits based on future contingencies are premature. Reapportionment of legislative districts can be done through a special law creating a new city, and the population requirement for an additional district was met.

Republic Act No. 7854 was enacted to convert the Municipality of Makati into a highly urbanized city. This conversion and specific provisions within the Act, such as the definition of its territory, the status of incumbent officials, and the creation of new legislative districts, prompted legal challenges from taxpayers and a senator who questioned their compliance with constitutional and statutory requirements.

• Republic Act No. 7854 converted the Municipality of Makati into a highly urbanized city.
• Petitioners in G.R. No. 118577, mostly taxpayers (only one a Makati resident), challenged Sections 2, 51, and 52 of R.A. No. 7854.
• Section 2 of R.A. No. 7854 defined the City of Makati's territory as comprising the "present territory of the Municipality of Makati," with a proviso regarding existing boundary disputes.
• Section 51 of R.A. No. 7854 provided that incumbent elective officials would continue in office and that the new city would acquire a new corporate existence.
• Section 52 of R.A. No. 7854 provided that upon conversion, Makati would have at least two legislative districts, reconfiguring the existing districts.
• Petitioner in G.R. No. 118627, Senator John H. Osmeña, challenged Section 52 of R.A. No. 7854 on similar grounds as the Mariano petitioners.
• At the time of R.A. No. 7854's consideration, a territorial dispute between Makati and Taguig over Fort Bonifacio was under court litigation.
• The 1990 census indicated Makati's population at 450,000.

• Section 2 of R.A. No. 7854 violates Section 10, Article X of the Constitution and Sections 7 and 450 of the Local Government Code because it does not identify Makati's land area by metes and bounds with technical descriptions.
• Section 51 of R.A. No. 7854, by stating the new city acquires a new corporate existence, attempts to alter or restart the three-consecutive term limit for local elective officials, violating Section 8, Article X and Section 7, Article VI of the Constitution, particularly favoring incumbent Mayor Jejomar Binay.
• Section 52 of R.A. No. 7854 is unconstitutional because it increased Makati's legislative district by a special law, not a general reapportionment law, as allegedly required by the Constitution.
• The increase in legislative districts under Section 52 was not expressed in the title of R.A. No. 7854, violating the "one subject-one title" rule in Section 26(1), Article VI of the Constitution.
• The addition of another legislative district in Makati under Section 52 is not in accord with Section 5(3), Article VI of the Constitution, as Makati's population (450,000 per 1990 census) is insufficient for two districts, each requiring 250,000.

• (As per Solicitor General's submission regarding Section 2) The requirement for metes and bounds in Sections 7 and 450 of the Local Government Code is a tool to reasonably ascertain territorial jurisdiction, not an end in itself; if jurisdiction can be reasonably ascertained by reference to common boundaries, the legislative intent is served.
• (As per Solicitor General's submission regarding Section 2) Requiring detailed technical descriptions akin to Torrens titles would defeat the Local Government Code's purpose of empowering local government units.
• (Inferred) The challenge to Section 51 regarding term limits is premature and speculative, lacking an actual case or controversy.
• (Inferred, based on Court's adoption of Tobias v. Abalos) Reapportionment of legislative districts can be made through a special law, such as a city charter.
• (Inferred, based on Court's adoption of Tobias v. Abalos) The title of R.A. No. 7854, "An Act Converting the Municipality of Makati Into a Highly Urbanized City," is sufficient, and the creation of legislative districts is germane to this general subject.
• (Inferred) Makati, with a population of 450,000, meets the minimum population requirement of 250,000 for at least one representative, and Congress has the power to increase districts if this minimum is met.

• Whether Section 2 of R.A. No. 7854 is unconstitutional for failing to define the City of Makati's territory by metes and bounds with technical descriptions.
• Whether Section 51 of R.A. No. 7854 is unconstitutional for allegedly restarting the three-term limit for incumbent elective officials of Makati.
• Whether Section 52 of R.A. No. 7854 is unconstitutional for increasing Makati's legislative districts through a special law, for allegedly not being expressed in the bill's title, and for allegedly not meeting the population requirement.

• Section 2 of R.A. No. 7854 is not unconstitutional; the delineation referring to the "present territory of the municipality" is sufficiently clear, especially since Congress intentionally avoided defining by metes and bounds due to an ongoing boundary dispute, respecting the judiciary's role. The requirement for metes and bounds is a tool, not an end in itself, as long as the territory is reasonably ascertainable.
• The challenge to Section 51 of R.A. No. 7854 is dismissed for prematurity; it is based on contingent events (Mayor Binay running, winning, and seeking re-election again) that do not constitute an actual case or controversy. Petitioners from Taguig are also not the proper parties. The Supreme Court has no jurisdiction over petitions for declaratory relief.
• Section 52 of R.A. No. 7854 is constitutional. Citing Tobias v. Abalos, the Court held that reapportionment of legislative districts can be made through a special law, like a city charter, and is not exclusively reserved for a general reapportionment law. The creation of legislative districts is germane to the general subject of converting a municipality into a city, satisfying the "one title-one subject" rule. Makati's population of 450,000 meets the minimum constitutional requirement of 250,000 for at least one representative, allowing Congress to increase its districts.

• Requirement of Metes and Bounds for LGU Territory — Sections 7 and 450 of the Local Government Code require that the area of a local government unit be identified by metes and bounds with technical descriptions. Applied in this case, the Court held that this requirement is a tool for reasonable ascertainment of territory and not an absolute, inflexible rule, especially when existing boundary disputes are pending judicial resolution. Congress's reference to the "present territory" was deemed sufficient under the circumstances.
• Actual Case or Controversy — For a court to exercise its power of judicial review, there must be an actual case or controversy involving a conflict of legal rights, an assertion of opposite legal claims susceptible of judicial resolution. Applied to the challenge against Section 51, the Court found the issue hypothetical and contingent on future events (Mayor Binay's electoral plans and success), thus lacking an actual case or controversy.
• Proper Party (Locus Standi) — A party challenging the constitutionality of a law must have a personal and substantial interest in the case such that they have sustained or will sustain direct injury as a result of its enforcement. Applied to the challenge against Section 51, petitioners who were residents of Taguig were deemed not the proper parties to raise the abstract issue concerning Makati's mayor.
• Declaratory Relief Jurisdiction — The Supreme Court does not have original jurisdiction over petitions for declaratory relief. This was mentioned in dismissing the challenge to Section 51, which was partly raised in a petition for declaratory relief.
• Reapportionment by Special Law — The Constitution (Art. VI, Sec. 5(1) "unless otherwise fixed by law") allows Congress to increase its membership by passing a law other than a general reapportionment law. Applied in this case, the Court affirmed that creating new legislative districts through a city charter (a special law) like R.A. No. 7854 is permissible.
• One Title-One Subject Rule (Art. VI, Sec. 26(1) of the Constitution) — Every bill passed by Congress shall embrace only one subject which shall be expressed in the title thereof. Applied to Section 52, the Court held that the creation of legislative districts is germane to the general subject of converting a municipality into a highly urbanized city, as expressed in the title of R.A. No. 7854. A liberal construction is favored so as not to impede legislation.
• Population Requirement for Legislative Districts (Art. VI, Sec. 5(3) of the Constitution) — A city with a population of at least 250,000 shall have at least one representative. Applied here, since Makati's population (450,000) exceeded the 250,000 minimum, Congress was empowered to increase its legislative districts.
• Statutory Construction (Legislative Intent) — Laws must be enforced when ascertained, even if not consistent with the strict letter, to uphold the true intent of the legislature and the general purpose of the act. Applied in interpreting the metes and bounds requirement, the Court prioritized the spirit of the Local Government Code, which is to empower LGUs, over a strict, literal interpretation that could hinder city creation due to pending disputes.

• "The importance of drawing with precise strokes the territorial boundaries of a local unit of government cannot be overemphasized. The boundaries must be clear for they define the limits of the territorial jurisdiction of a local government unit."
• "We hold that the existence of a boundary dispute does not per se present an insurmountable difficulty which will prevent Congress from defining with reasonable certitude the territorial jurisdiction of a local government unit."
• "To invalidate R.A. No. 7854 on the mere ground that no cadastral type of description was used in the law would serve the letter but defeat the spirit of the Code. It then becomes a case of the master serving the slave, instead of the other way around."
• "The requirements before a litigant can challenge the constitutionality of a law are well-delineated. They are: (1) there must be an actual case or controversy; (2) the question of constitutionality must be raised by the proper party; (3) the constitutional question must be raised at the earliest possible opportunity; and (4) the decision on the constitutional question must be necessary to the determination of the case itself."
• "Sovereignty cannot admit of any kind of subtraction. It is indivisible. It must be forever whole or it is not sovereignty."
• "To be sure, the Constitution does not command that the title of a law should exactly mirror, fully index, or completely catalogue all its details. Hence, we ruled that ‘it should be sufficient compliance if the title expresses the general subject and all the provisions are germane to such general subject.’"

• Tobias v. Abalos (G.R. No. 114783, December 8, 1994) — Cited as controlling precedent for the ruling that reapportionment of legislative districts may be made through a special law (like a city charter), that the "one title-one subject" rule should be liberally construed, and that an increase in legislative districts is germane to the creation of a city.
• Torres v. Limjap (56 Phil. 141) — Cited as authority for the principle that courts will not follow the letter of the statute when doing so would depart from the true legislative intent or yield conclusions inconsistent with the act's general purpose.
• Tañada v. Cuenco (103 Phil. 1051) — Cited alongside Torres v. Limjap for the same principle of statutory construction regarding legislative intent.
• Hidalgo v. Hidalgo (33 SCRA 1105) — Cited alongside Torres v. Limjap for the same principle of statutory construction regarding legislative intent.
• Bocobo v. Estanislao (72 SCRA 520) — Cited for the principle that laws have ends to achieve, and statutes should be construed to carry out such ends and purposes, not defeat them.
• Dumlao v. COMELEC (95 SCRA 392 (1980)) — Cited as the source for the four requirements for challenging the constitutionality of a law.

• Republic Act No. 7854, Section 2 — Subject of the challenge regarding territorial delineation. The Court upheld its constitutionality.
• Republic Act No. 7854, Section 51 — Subject of the challenge regarding the three-term limit. The Court dismissed the challenge as premature.
• Republic Act No. 7854, Section 52 — Subject of the challenge regarding the creation of legislative districts. The Court upheld its constitutionality.
• Constitution, Article X, Section 10 (Creation of LGUs) — Requires creation of LGUs to be in accordance with criteria in the LGC. Petitioners argued Sec. 2 of RA 7854 violated this. The Court found no violation.
• Constitution, Article X, Section 8 (Term Limits of Local Officials) — Provides for a three-year term and a maximum of three consecutive terms for local elective officials. Petitioners argued Sec. 51 of RA 7854 violated this. The Court found the challenge premature.
• Constitution, Article VI, Section 7 (Term of Office of Representatives) — Provides for a three-year term for Members of the House of Representatives and a three-consecutive term limit. Referenced by petitioners in relation to the term limit argument for local officials.
• Constitution, Article VI, Section 5(1) (Composition of House of Representatives) — States Congress shall be composed of not more than 250 members, "unless otherwise fixed by law." The Court interpreted this to allow Congress to increase its membership by laws other than a general reapportionment law, such as a city charter.
• Constitution, Article VI, Section 5(3) (Legislative Districts Population Requirement) — Requires each city with at least 250,000 inhabitants to have at least one representative. The Court found Makati met this for an increase in districts.
• Constitution, Article VI, Section 5(4) (Reapportionment by Congress) — Mandates Congress to make a reapportionment within three years after every census. Petitioners argued Sec. 52 violated this by creating districts via special law. The Court disagreed.
• Constitution, Article VI, Section 26(1) (One Subject-One Title Rule) — Requires every bill to embrace only one subject expressed in its title. Petitioners argued Sec. 52 violated this. The Court found no violation.
• Local Government Code (R.A. No. 7160), Section 7 (Creation and Conversion of LGUs) — Specifies criteria for LGU creation, including identification of land area by metes and bounds. The Court interpreted this flexibly.
• Local Government Code (R.A. No. 7160), Section 450 (Requisites for City Creation) — Subsection (b) requires the territorial jurisdiction of a newly-created city to be properly identified by metes and bounds. The Court found this provision primarily applicable to component cities and that the general principle was satisfied for a highly urbanized city like Makati.
• Ordinance Appended to the Constitution, Section 3 — Provides that a city whose population increases to more than 250,000 shall be entitled to at least one congressional representative. The Court cited this to support that Makati, with over 250,000, could have its districts increased.

• Justice Hilario G. Davide, Jr. — He agreed with the ponencia but added that the constitutional requirement for description by metes and bounds in Section 7 of the Local Government Code is qualified by "as a general rule." He further argued that Section 450(b) of the LGC, requiring metes and bounds for a "newly created city," applies specifically to the conversion of a municipality or cluster of barangays into a COMPONENT CITY, not a highly urbanized city like Makati. Regarding the increase in legislative seats, he opined that this is permissible under Sections 1 and 3 of the Ordinance appended to the Constitution, which allows for adjustments when a city's population increases beyond 250,000, rather than solely relying on the "unless otherwise fixed by law" clause of Article VI, Section 5(1) of the Constitution, which he believes refers to a general reapportionment law.