Lidasan vs COMELEC

on November 12, 2011

Political Law Effect if Title Does Not Completely Express the Subject Lidasan is a resident of Parang, Cotabato. Later, RA 4790, which is entit ed !An Act Creating the M"nici#a it$ of %ianaton in the Province of Lanao de &"r,' was #assed. Lidasan ca(e to )now ater on that barrios *ogaig and Mada "( +"st (entioned are within the ("nici#a it$ of ," don, Province of Cotabato, and that ,a$anga, Lang)ong, &ara)an, -at.bo, %iga)a#an, Magabo, *abangao, *iong)o, Co odan, and -aba(a)awan are #arts and #arce of another ("nici#a it$, the ("nici#a it$ of Parang, a so in the Province of Cotabato and not of Lanao de &"r. /Re(ar)ab $, even the Congress(an of Cotabato voted in favor of RA 4790.0 P"rs"ant to this aw, COMELEC #roceeded to estab ish #recints for voter registration in the said territories of %ianaton. Lidasan then fi ed that RA 4790 be n" ified for being "nconstit"tiona beca"se it did not c ear $ indicate in its tit e that it in creating %ianaton, it wo" d be inc "ding in the territor$ thereof barrios fro( Cotabato. ISSUE: 1s RA 4790, which created %ianaton b"t which inc "des barrios ocated in another #rovince 2 Cotabato 2 to be s#ared fro( attac) # anted "#on the constit"tiona (andate that !3o bi which (a$ be enacted into aw sha e(brace (ore than one s"b+ect which sha be e4#ressed in the tit e of the bi 5 HELD: *he banef" effect of the defective tit e here #resented is not so diffic" t to #erceive. &"ch tit e did not infor( the (e(bers of Congress as to the f" i(#act of the aw6 it did not a##rise the #eo# e in the towns of ," don and Parang in Cotabato and in the #rovince of Cotabato itse f that #art of their territor$ is being ta)en awa$ fro( their towns and #rovince and added to the ad+acent Province of Lanao de &"r6 it )e#t the #"b ic in the dar) as to what towns and #rovinces were act"a $ affected b$ the bi that even a Congress(an fro( Cotabato voted for it on $ to find o"t ater on that it is to the #re+"dice of his own #rovince. *hese are the #ress"res which heavi $ weigh against the constit"tiona it$ of RA 4790.