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TOBIAS V.

ABALOS
Section 26.
1. Every bill passed by the Congress shall embrace only one subject which shall be expressed in the title thereof.
Doctrine: A liberal construction of the “one title one subject rule” has been
invariably adopted by the Supreme Court so as not to cripple or impede legislation.
Article 6 !6"a# should be given a practical rather than a technical construction. $t
should be su%cient compliance &ith such re'uirement if the title e(presses the
general subject and all the provisions are germane to that general subject.
FACTS
The petitioners, in their capacity as taxpayers and residents of Mandaluyong, assail
the constitutionality of RA No. 7675, otherwise known as An Act !on"erting the
Municipality of Mandaluyong into a #ighly $r%ani&ed !ity to %e 'nown as !ity of
Mandaluyong(. )rior to the enact*ent of the assailes statute, the *unicipalities of
Mandaluyong and +an ,uan %elonged to only one legislati"e district.
)etitioners allege that the said law resulted in e*%racing two principal su%-ects
na*ely. /. The con"ersion of Mandaluyong into a highly ur%ani&ed city and 0. The
di"ision of the congressional district of +an ,uan1Mandaluyong into two separate
districts. )etitioners contend that the second aforestated su%-ect is not ger*ane to
the su%-ect *atter of R.A. No. 7675 since the said law treats of the con"ersion of
Mandaluyong into a highly ur%ani&ed city, as expressed in the title of the law.
ISSUE
23N the pro"isions of RA No. 7675 contra"enes the one su%-ect one rule( of the
!onstitution. 4N356
HELD
The contentions are de"oid of *erit.
!ontrary to petitioners7 assertion, the creation of a separate congressional district
for Mandaluyong is not a su%-ect separate and distinct fro* the su%-ect of its
con"ersion into a highly ur%ani&ed city %ut is a natural and logical conse8uence of
its con"ersion into a highly ur%ani&ed city. The title of R.A. No. 7675 necessarily
includes and conte*plates the su%-ect treated under +ection 9: regarding the
creation of a separate congressional district for Mandaluyong.
Moreo"er, a li%eral construction of the ;one title<one su%-ect; rule has %een
in"aria%ly adopted %y this court so as not to cripple or i*pede legislation. Thus,
in Sumulong v. Comelec) the !ourt ruled that the constitutional re8uire*ent as now
expressed in Article =>, +ection 064/6 ;should %e gi"en a practical rather than a
technical construction. >t should %e su?cient co*pliance with such re8uire*ent if
the title expresses the general su%-ect and all the pro"isions are ger*ane to that
general su%-ect.;