Lidasan vs COMELEC

Political Law Effect if Title Does Not Completely Express the Subject
Lidasan is a resident of Parang, Cotabato. Later, RA 4790, which is entitled An Act Creating the
Municipality of Dianaton in the Province of Lanao del Sur, was passed. Lidasan came to know later on
that barrios Togaig and Madalum just mentioned are within the municipality of Buldon, Province of
Cotabato, and that Bayanga, Langkong, Sarakan, Kat-bo, Digakapan, Magabo, Tabangao, Tiongko,
Colodan, and Kabamakawan are parts and parcel of another municipality, the municipality of Parang,
also in the Province of Cotabato and not of Lanao del Sur. [Remarkably, even the Congressman of
Cotabato voted in favor of RA 4790.] Pursuant to this law, COMELEC proceeded to establish precints for
voter registration in the said territories of Dianaton. Lidasan then filed that RA 4790 be nullified for
being unconstitutional because it did not clearly indicate in its title that it in creating Dianaton, it would
be including in the territory thereof 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: 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.

Facts: RA 4790, entitled "An Act Creating the Municipality of Dianaton in the Province of Lanao del
Sur, took effect on June 18, 1966. It sought to create the new municipality of Dianaton within barrios in
Lanao del Sur, but also included barrios located in Cotabato. Bara Lidasan, a resident and taxpayer of
the detached portion of Parang, Cotabato requested for certiorari and prohibition and declare RA 4790
as unconstitutional because its Title is misleading and invoked the provision of the Constitution that the
title of a bill is to be couched in a language sufficient to notify the legislators and the public and those
concerned of the import of the single subject thereof.

Issue: Whether the title of RA 4790 "An Act Creating the Municipality of Dianaton in the Province of
Lanao del Sur" satisfied the provision of the Constitution that the title of an act must be sufficient to
notify the public and others concerned of its substance.

Decision: RA4970, An Act Creating the Municipality of Dianaton, in the Province of Lanao del Sur, is
deemed unconstitutional. The very title projected the impression that Lanao del Sur is the only
province affected by the act. This statute apprised neither Congress nor the people in the towns of
Buldon and Parang in Cotabato and in the province of Cotabato that part of Cotabatos territory is being
taken to add to the adjacent Lanao del Sur.