Lidasan v. COMELEC G.R. No.

L-28089, October 25, 1967 Ponente: Justice Sanchez Facts: In 1966, the Chief Executive enacted RA4790, now in dispute, creating the municipality of Dianaton, Lanao del Sur. Some barrios mentioned where within other municipalities in other provinces. COMELEC then adopted a resolution which included said barrios under the new municipality, changing the boundaries of the provinces. The office of the President said recommended COMELEC that the operation of the statute be suspended until clarified, but COMELEC stood by its own interpretation, saying that the statute should be implemented until clarified by correcting legislation. Petitioner then filed an original action for certiorari and prohibition as a resident and taxpayer of the detached portion of Parang, Cotabato, and a qualified voter for the 1967 elections, praying that the RA be invalidated since it embraced more than one subject as against its bills title. Issue: Whether or not said statute is valid. Held: No. Congress must refrain from conglomeration of heterogenous subjects, so the title of the bill must be couched in a language sufficient to notify legislators and the public and those concerned of the import (nature, scope, consequences, operation) of the single subject thereof. It is a constitutional requirement breathing the spirit of the command, especially when on the first reading, Congress is not obligated to read the entire bill. The test is whether or not the title is misleading, or whether or not the title is so uncertain that the average person would not be informed of the purpose of its enactment. The title "An Act Creating the Municipality of Dianaton, in the Province of Lanao del Sur"8 projects that only said province is affected by the creation, not the thought that communities of the adjacent province are incorporated in the new town. The RA creates the municipality from 21 barrios from other towns, and dismembers two municipalities in another province. Transfer of a sizeable portion of territory from one province to another of necessity involves reduction of area, population and income of the first and the corresponding increase of those of the other. This is as important as the creation of a municipality. And yet, the title did not reflect this fact. Salvaging the bill is impossible (enough must remain to make an intelligible and valid statute, carrying our the legislative intent), for knowing that Dianaton was created upon considerations of progressive community, large aggregate population, and sufficient income, it may be said that Congress intended the creation with all included barrios and not only those salvageable.