Lidasan v.

COMELEC, 21 SCRA 479 (1967)

 Republic Act 4790 created the Municipality of Dianaton in the Province of Lanao del
Sur, but it included 12 barrios that were part of the municipalities of Buldon and
Parang in the Province of Cotabato.

 The Commission on Elections (COMELEC) issued a resolution implementing RA 4790

for the purposes of the 1967 elections.

 Bara Lidasan, a resident and taxpayer of Parang, Cotabato, filed a petition for
certiorari and prohibition, challenging the constitutionality of RA 4790 and the
COMELEC resolution1.

Issue:

 Whether RA 4790 violates the constitutional requirement that no bill shall embrace
more than one subject which shall be expressed in the title of the bill.

Ruling:

 The Supreme Court held that RA 4790 is unconstitutional because it violates the one-
subject-one-title rule.

 The Court reasoned that the title of RA 4790 only states that it creates the
Municipality of Dianaton in the Province of Lanao del Sur, but it does not mention or
imply that it also transfers 12 barrios from Cotabato to Lanao del Sur.

 The Court said that the title of the bill should have clearly indicated the change of
territorial boundaries of the affected provinces and municipalities, as this is a matter
of public interest and convenience.

 The Court also noted that the transfer of 12 barrios from Cotabato to Lanao del Sur
affects the political and economic rights of the people living in those areas, as well as
the autonomy and representation of the local governments involved.

 The Court declared RA 4790 null and void, and ordered the COMELEC to desist from
implementing it.

Important Notes:

 This case illustrates the importance of the one-subject-one-title rule as a safeguard

against legislative deception and logrolling.

 Logrolling is the practice of combining unrelated or controversial matters in one bill

to secure its passage by trading votes among legislators.

 The one-subject-one-title rule aims to prevent the passage of bills that contain
hidden or unrelated provisions that the legislators and the public may not be aware
of or may not approve of.

 The rule also facilitates the understanding and enactment of bills by requiring that
they have a clear and concise title that reflects their contents.
 The rule is not violated if the title is comprehensive enough to include the general
purpose and scope of the bill, and all the provisions are germane to that purpose
and scope.

 However, the rule is violated if the title is misleading, deceptive, or inaccurate, or if it

conceals the real subject of the bill, or if it fails to inform the legislators and the
public of the nature and consequences of the bill.