Tobias vs.

Abalos
Facts:
In this case the petitioners assail the constitutionality of R.A. 7675, otherwise known as An Act
Converting the Municipality of Mandaluyong into a Highly Urbanized City to be Known as the City of
Mandaluyong. Prior to the enactment of the statute the Municipalities of Mandaluyong and San Juan
belonged to only one legislative district. On April 10, 1994 a plebiscite was held. The people of
Mandaluyong were asked whether they approved of the conversion of the Municipality of Mandaluyong
into a highly urbanized city. The turnout was only 14.41% of the voting population. Nevertheless 18,621
voted yes while 7,911 voted no. By virtue of these results, R.A. No. 7675 was deemed ratified and in
effect.
Issue:
WON R.A. No. 7675 was in violation of Article VI Sec. 26(1) and Sec 5(1) of the constitution.
Held:
No. Art. VI Sec. 26 (1) of the constitution states that Every bill passed by Congress shall embrace only
one subject which shall be expressed in the title thereof. Contrary to petitioners assertion, the creation
of a separate district for Mandaluyong is not a subject separate and distinct from the subject of its
conversion into a highly urbanized city but is a natural and logical consequence of its conversion into a
highly urbanized city.
As to the contention that the assailed law violates the present limit on the number of representatives as
set forth in the Constitution, a reading of the applicable provision, Art. VI Sec. 5(1) shows that the
present limit of 250 members is not absolute. The Constitution clearly provides that the House of
Representatives shall be composed of not more than 250 members , unless otherwise provided by
law. This means the present composition of Congress may be increase, if Congress itself so mandates
through a legislative enactment. Therefore, the increase in congressional representation mandated by
R.A. 7675 is not unconstitutional.
The petition was DISMISSED for lack of merit.






Puyat vs. De Guzman
Facts:
On 14 May 1979, the Puyat group were elected as directors of the International Pipe Industries (IPI)
Thus the Puyat group would be in control of the Board and management of IPI. The election was
subsequently questioned by the Acero group claiming that the votes were not properly counted hence
the filed quo warranto proceeding before the Securities and Exchange Commission on 25 May 1979.
Prior to the Acero groups filing of the case, Justice Estanislao Fernandez, then a member of the Interim
Batasang Pambansa purchased ten shares of stock of IPI from a member of Aceros group, the deed of
sale was notarized on May 30, 1979 only. And during a conference held by SEC Commissioner de
Guzman (from May 25-31 79) to have the parties confer with each other, Estanislao Fernandez entered
his appearance as counsel for Acero. Puyat group objected arguing that it is unconstitutional for an
assemblyman to appear as counsel before any administrative body and SEC was an administrative body.
The cited Constitutional prohibition being clear, Assemblyman Fernandez did not continue his
appearance for Acero. On May 31, the day following the notarization of his purchase he filed an Urgent
Motion for Intervention in this said SEC case for him to intervene not as a counsel but as a legal owner
of IPI shares and as a person who has a legal interest in the matter in litigation. The SEC Commissioner
granted leave to intervene. Puyat then moved to question the Commissioners action. On the basis of
Atty. Fernandez ownership of the said ten shares.
Issue:
WON Assemblyman Fernandez, as a then stockholder of IPI may intervene in the SEC case without
violating Section 11, Article VIII of the Constitution providing that an assemblyman must not appear as
counsel before any court without appellate jurisdiction or before any administrative body.
Held:
No. A ruling upholding the intervention would make the constitutional provision ineffective. All an
Assemblyman need do, if he wants to influence an administrative body is to acquire a minimal
participation in the interest of client and then intervene in the proceedings. In this case there has
been a circumvention of the Constitutional prohibition. The intervention was an afterthought to
enable him to appear actively in the proceedings in some other capacity.
The respondent Commissioners Order granting Atty. Estanislao Fernandez leave to intervene in SEC
Case No. 1747 is hereby reversed and set aside.




Angara vs. De Venecia
Facts:
A petition was filed challenging the validity of RA 8240, which amends certain provisions of the National
Internal Revenue Code by imposing so-called sin taxes on the manufacture and sale of beer and
cigarettes. The petitioners are members of the House of Representatives. They charged that there is
violation of the rules of the House which petitioners claim are constitutionally mandated so that their
violation is tantamount to a violation of the Constitution.

The law originated in the House of Representatives. The Senate approved it with certain amendments. A
bicameral conference committee was formed to reconcile the disagreeing provisions of the House and
Senate versions of the bill. The bicameral committee submitted its report to the House. During the
interpellations, Rep. Arroyo made an interruption and moved to adjourn for lack of quorum. But after a
roll call, the Chair declared the presence of a quorum. The interpellation then proceeded. After Rep.
Arroyos interpellation of the sponsor of the committee report, Majority Leader Albano moved for the
approval and ratification of the conference committee report. The Chair called out for objections to the
motion. Then the Chair declared: There being none, approved. At the same time the Chair was saying
this, Rep. Arroyo was asking, What is thatMr. Speaker? The Chair and Rep. Arroyo were talking
simultaneously. Thus, although Rep. Arroyo subsequently objected to the Majority Leaders motion, the
approval of the conference committee report had by then already been declared by the Chair,
symbolized by its banging of the gavel.

On the same day, the bill was signed by the Speaker of the House of Representatives and the President
of the Senate and certified by the respective secretaries of both Houses of Congress. The enrolled bill
was signed into law by President Ramos.
ISSUE:
WON R.A. No. 8240 is null and void because it was passed in violation of the rules of the House.
Held:
No. Rules are hardly permanent in character. The prevailing view is that they are subject to revocation,
modification or waiver at the pleasure of the body adopting them as they are primarily procedural.
Courts ordinarily have no concern with their observance. They may be waived or disregarded by the
Legislative body. Consequently, mere failure to conform to them does not have the effects of nullifying
the act taken if the requisite number of members has agreed to a particular measure. In this case no
rights of private individuals are involved but only those of a member who, instead of seeking redress in
the House, chose to transfer the dispute to this Court. The courts have no more power to look into the
internal proceedings of a House than members of that House have to look over the shoulders of the
court, as long as no violation of constitutional provisions is shown.