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.

People vs. Echavez

Petitioner Ello filed with the lower court separate informations against sixteen
persons charging them with squatting as penalized by Presidential Decree No.
772. Before the accused could be arraigned, respondent Judge Echaves motu
proprio issued an omnibus order dismissing the five informations (out of 16 raffled)
on the grounds (1) that it was alleged that the accused entered the land through
stealth and strategy, whereas under the decree the entry should be effected with
the use of force, intimidation or threat, or taking advantage of the absence or

tolerance of the landowner, and (2) that under the rule of ejusdem generis the
decree does not apply to the cultivation of a grazing land. From the order of
dismissal, the fiscal appealed to this Court under Republic Act No. 5440.
ISSUE:
Whether or not P.D. No. 772 which penalizes squatting and similar acts, (also) apply
to agricultural lands.
HELD:
NO. Appeal was devoid of merit.Trial courts dismissal was affirmed.
RATIO:
[T]he lower court correctly ruled that the decree does not apply to pasture lands
because its preamble shows that it was intended to apply to squatting in urban
communities or more particularly to illegal constructions in squatter areas made by
well-to-do individuals. The squating complained of involves pasture lands in rural
areas.
The rule of ejusdem generis (of the same kind or species) invoked by the trial court
does not apply to this case. Here, the intent of the decree is unmistakable. It is
intended to apply only to urban communities, particularly to illegal constructions.
The rule of ejusdem generis is merely a tool of statutory construction which is
resorted to when the legislative intent is uncertain.

The Director of Posts announced on May 1936 in Manila newspapers that he would order the
issuance of postage stamps for the commemoration of the 33rd International Eucharistic
Congress celebration in the City of Manila. The said event was organized by the Roman
Catholic Church. Monsignor Gregorio Aglipay, the petitioner, is the Supreme Head of the
Philippine Independent Church, requested Vicente Sotto who is a member of the Philippine Bar
to raise the matter to the President. The said stamps in consideration were actually issued
already and sold though the greater part thereof remained unsold. The further sale of the
stamps was sought to be prevented by the petitioner.
Issue:
Whether or not the respondent violated the Constitution in issuing and selling postage stamps
commemorative of the Thirty-third International Eucharistic Congress
Held:
No, the respondent did not violate the Constitution by issuing and selling the commemorative

postage stamps. Ruiz acted under the provision of Act No. 4052, which contemplates no
religious purpose in view, giving the Director of Posts the discretion to determine when the
issuance of new postage stamps would be advantageous to the Government. Of course, the
phrase advantageous to the Government does not authorize the violation of the Constitution.
In the case at bar, the issuance of the postage stamps was not intended by Ruiz to favor a
particular church or denomination. The stamps did not benefit the Roman Catholic Church, nor
were money derived from the sale of the stamps given to that church. The purpose of issuing of
the stamps was to actually take advantage of an international event considered to be a great
opportunity to give publicity to the Philippines and as a result attract more tourists to the country.
In evaluating the design made for the stamp, it showed the map of the Philippines instead of
showing a Catholic chalice. The focus was on the location of the City of Manila, and it also bore
the inscription that reads Seat XXXIII International Eucharistic Congress, Feb. 3-7, 1937. In
considering these, it is evident that there is no violation of the Constitution therefore the act of
the issuing of the stamps is constitutional.
The Supreme Court denied the petition for a writ of prohibition, without pronouncement as to
costs.