Bara Lidasan vs Commission on Elections
21 SCRA 496 – Political Law – Effect if Title Does Not Completely Express the Subject
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.