LIDASAN V.

COMELEC
Topic: Title of Bills

FACTS

Bara Lidasan was a resident of Parang, Cotabato. Later, Republic Act No.
4790, entitled “An Act Creating the Municipality of Dianaton in the Province
of Lanao del Sur,” was passed. Lidasan however discovered that certain
barrios located in Cotabato were included in Dianaton, Lanao Del Sur
pursuant to RA 4790. [Remarkably, even the Congressman of Cotabato
voted in favor of RA 4790.] Pursuant to this law, COMELEC proceeded to
establish precincts for voter registration in the said territories of Dianaton.
Lidasan then filed a case to have RA 4790 be nullified for being
unconstitutional. He averred that the law did not clearly indicate in its title
that in creating Dianaton, it would be including in its territory several barrios
from Cotabato.

ISSUE: Is RA 4790, which created Dianaton but which includes barrios

located in another province – Cotabato – to be spared from attack planted
upon the constitutional mandate that “No bill which may be enacted into
law shall embrace more than one subject which shall be expressed in
the title of the bill”?

HELD: No. The said law is void. The baneful effect of the defective title
here presented is not so difficult to perceive. Such title did not inform the
members of Congress as to the full impact of the law; it did not apprise the
people in the towns of Buldon and Parang in Cotabato and in the province
of Cotabato itself that part of their territory is being taken away from their
towns and province and added to the adjacent Province of Lanao del Sur; it
kept the public in the dark as to what towns and provinces were actually
affected by the bill that even a Congressman from Cotabato voted for it
only to find out later on that it is to the prejudice of his own province. These
are the pressures which heavily weigh against the constitutionality of RA
4790.