Case Digest: Giron vs. COMELEC

G.R. No. 188179, January 22, 2013

HENRY R. GIRON, Petitioner, v. COMMISSION ON ELECTIONS, Respondent, ALMARIO E. FRANCISCO, FEDERICO S. JONG JR., and RICARDO L. BAES JR., Petitioners-in-Intervention.

SERENO, CJ:


FACTS:

Petitioner Henry Giron (Giron) and petitioners-in-intervention assail the constitutionality of Section 12 (Substitution of Candidates) and Section 14 (Repealing Clause) of Republic Act No. (R.A.)9006, otherwise known as the Fair Election Act.

Giron asserts that the insertion of Sections 12 and 14 in the Fair Election Act violates Section 26(1), Art. VI of the 1987 Constitution, which specifically requires: “Every bill passed by the Congress shall embrace only one subject which shall be expressed in the title thereof.” He avers that these provisions are unrelated to the main subject of the Fair Election Act: the lifting of the political ad ban. Section 12 refers to the treatment of the votes cast for substituted candidates after the official ballots have been printed, while Section 14 pertains to the repeal of Section 67 (Candidates holding elective office) of Batas Pambansa Blg. 881, otherwise known as the Omnibus Election Code. Section 67 of this law concerns the ipso facto resignation of elective officials immediately after they file their respective certificates of candidacy for an office other than that which they are currently holding in a permanent capacity.

ISSUE: Whether or not the inclusion of Sections 12 and 14 in the Fair Election Act violates Section 26(1), Article VI of the 1987 Constitution, or the “one subject-one title” rule?

HELD: The petition must fail.

POLITICAL LAW: “one subject-one title” rule


It is a well-settled rule that courts are to adopt a liberal interpretation in favor of the constitutionality of a legislation, as Congress is deemed to have enacted a valid, sensible, and just law. Because of this strong presumption, the one who asserts the invalidity of a law has to prove that there is a clear, unmistakable, and unequivocal breach of the Constitution; otherwise, the petition must fail.

The Court finds that the present case fails to present a compelling reason that would surpass the strong presumption of validity and constitutionality in favor of the Fair Election Act.

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. The requirement that the subject of an act shall be expressed in its title should receive a reasonable and not a technical construction. It is sufficient if the title be comprehensive enough reasonably to include the general object which a statute seeks to effect, without expressing each and every end and means necessary or convenient for the accomplishing of that object. Mere details need not be set forth. The title need not be an abstract or index of the Act.

Moreover, the avowed purpose of the constitutional directive that the subject of a bill should be embraced in its title is to apprise the legislators of the purposes, the nature and scope of its provisions, and prevent the enactment into law of matters which have not received the notice, action and study of the legislators and the public.

DISMISSED.

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