Tañada vs. Tuvera (G.R. No.

L-63915, April 24, 1985)

Facts: Petitioners, citing the right to be informed under Section 6, Article IV of the 1973
Constitution, sought a writ of mandamus to compel respondents to publish presidential issuances
in the Official Gazette, arguing that laws must be published to be valid and enforceable. The
respondents, through the Solicitor General, argued that petitioners lacked legal standing, as they
were not directly affected by the failure to publish the issuances, and called for dismissal.
Petitioners countered that the case involves a public right and duty, so no personal interest is
needed. Respondents further argued that publication in the Official Gazette is unnecessary when
laws specify their own effective dates.

Issue:
1. Whether or not the petitioners have legal standing to institute a mandamus proceeding
compelling respondents to cause the publication of various presidential issuances in the
Official Gazette.
2. Whether or not publication in the Official Gazette is a requirement for the effectivity of
the presidential issuances, regardless of the laws specifying their own effectivity dates.

Ruling:
1. The Court confirmed that petitioners have legal standing, as the case involves the public's
constitutional right to be informed, as per the 1973 Philippine Constitution. Since the
petition seeks to enforce a public duty, petitioners, as concerned citizens, do not need to
show a specific interest. This follows precedents like Severino vs. Governor General,
where private individuals were allowed to bring a case when a public right is involved.
2. The Court ruled that publication is required for the effectivity of presidential issuances.
While some issuances specify their own effective dates, those with general applicability
still require publication in the Official Gazette, as per Section 1 of Commonwealth Act
638. The Court emphasized that publication ensures transparency and fulfills the
constitutional right to be informed on public matters.

Umali vs. Estanislao (G.R. No. 104037, May 29, 1992)

Facts: Republic Act No. 7167, enacted on December 19, 1991, increased the basic personal and
additional exemptions for income tax, with the law taking effect after its publication on January
14, 1992. However, the respondents issued Revenue Regulations No. 1-92 on December 26,
1991, which postponed its implementation until January 1, 1992. In response, two petitions were
filed, seeking to compel the respondents to apply the law to taxable income for 1991 and to block
the implementation of the regulations. The Court consolidated the cases on March 10, 1992.

Issue:
1. Whether or not RA No. 7167 took effect on December 19, 1991, upon presidential
approval, or on January 30, 1992, after its publication on January 14, 1992.
2. Whether or not the said law applies to compensation income earned or received in 1991.

Ruling:
 1. The Court ruled that Republic Act No. 7167 took effect on January 30, 1992, after its
publication in the "Malaya" newspaper on January 14, 1992, as required by Article 2 of
the Civil Code. Although signed by the President on December 19, 1991, the law did not
specify immediate effect, necessitating the 15-day publication period. Citing Caltex
(Phils.), Inc. v. Commissioner of Internal Revenue, the Court confirmed that laws take
effect 15 days after publication unless otherwise stated, making the law effective on
January 30, 1992.
2. The Court ruled that RA No. 7167 applies to 1991 compensation income, aiming to adjust
exemptions for inflation and rising costs. Although effective on January 30, 1992, the
law's increased exemptions were meant to apply retroactively to 1991. Despite the
Commissioner of Internal Revenue's attempt to delay implementation with Revenue
Regulations No. 1-92, the Court upheld that the law's purpose was to reduce the 1991 tax
burden. Thus, taxpayers who filed without the increased exemptions were entitled to
refunds or credits.

Fariñas vs. Executive Secretary (G.R. No. 147387, December 10, 2003)

Facts: The case involves petitions challenging the constitutionality of Section 14 of RA No.
9006, which repeals Section 67 of the Omnibus Election Code. Petitioners argue this repeal is not
reflected in the law’s title, making it an improper rider, and claim it unfairly discriminates against
appointive officials, violating the equal protection clause. They also contend that RA No. 9006 is
void due to enactment irregularities, including an immediate effectivity clause violating the due
process requirement for publication. Respondents, however, argued for dismissal, asserting
petitioners lack standing, the law’s broad title covers all election processes, and the distinction
between elective and appointive officials justifies differing treatment. They also invoked the
enrolled bill doctrine to dismiss claims of procedural irregularities.

Issues:
1. Whether or not Section 14 of RA No. 9006 is unconstitutional for violating the one-
subject rule outlined in the 1987 Constitution.
2. Whether or not the repeal of Section 67 of the Omnibus Election Code violates the equal
protection clause.
3. Whether or not irregularities occurred during the enactment of RA No. 9006.
4. Whether or not the effectivity clause of RA No. 9006 is valid.

Ruling:
1. The Court ruled that Section 14 of Republic Act No. 9006 is not unconstitutional and
does not violate the one-subject rule. It noted that the law’s title, focused on improving
free and fair elections, is broad enough to include the repeal of Section 67 of the
Omnibus Election Code. The Court explained that a law's title should reflect its purpose,
allowing provisions that support its overall goal, and that removing Section 67 aligned
with the law's aim of promoting fair elections.
2. The Court held that repealing Section 67 does not go against the equal protection clause
of the Constitution. It explained that there are important differences between elected and
appointed officials, which justifies treating them differently under the law. The Court
 added that the equal protection clause does not stop reasonable classifications based on
these real differences.
3. The Court found no significant irregularities in the creation of Republic Act No. 9006
that would invalidate the law. Following the enrolled bill doctrine, it assumed the bill was
properly passed since it was signed by legislative leaders and certified by the secretaries
of both houses. The Court concluded that any alleged irregularities were minor
procedural issues and did not violate the Constitution.
4. The Court found that the effectivity clause was flawed but did not make the entire law
invalid. Although the clause stated that the law would take effect immediately upon
approval, the Court ruled that it would still take effect 15 days after publication, as per
standard legal rules.

La Bugal-B’laan Tribal Association, Inc. vs. Ramos (G.R. No. 127882, December 1, 2004)

Facts: The case of La Bugal-B'laan Tribal Association, Inc. v. Ramos centers on the
constitutionality of Republic Act No. 7942 (Philippine Mining Act of 1995), its Implementing
Rules (DENR Administrative Order No. 96-40), and a Financial and Technical Assistance
Agreement (FTAA) between the Philippine government and Western Mining Corporation
(Philippines), Inc. Petitioners, led by Chairman F'long Miguel M. Lumayong of the La Bugal-
B'laan Tribal Association, argued that these measures violated Section 2, Article XII of the 1987
Constitution, which mandates that the State fully control natural resource exploration and use.
The Supreme Court initially ruled on January 27, 2004, that parts of RA 7942, DAO 96-40, and
the FTAA were unconstitutional. However, after reconsideration motions, a new resolution was
issued on December 1, 2004.

Issues:
1. Whether or not the case has been rendered moot by the sale of WMC shares in WMCP to
Sagittarius, a Filipino-owned corporation.
2. Whether or not it would still be proper to resolve the constitutionality of the challenged
provisions of the Mining Law, DAO 96-40, and the WMCP FTAA, assuming the case has
been rendered moot.
3. Whether or not the proper interpretation of the phrase “Agreements Involving Either
Technical or Financial Assistance” in paragraph 4 of Section 2 of Article XII of the
Constitution has been established.

Ruling:
The Supreme Court granted the respondents’ and intervenors’ motions for reconsideration,
overturning its earlier decision from January 27, 2004.
1. The Court ruled that the sale of WMC shares to a Filipino-owned corporation made the
foreign ownership issue moot, as the FTAA would not be managed by a qualified Filipino
corporation. The Court further explained that the Constitution should foster economic
growth and attract foreign investments, while ensuring that the State retains control over
natural resources.
2. The Court upheld the constitutionality of RA No. 7942 (Philippine Mining Law) and its
IRR (DOA 96-40) in relation to financial and technical assistance. It also affirmed the
 FTAA dated March 30, 1995, except for Sections 7.8 and 7.9, which were invalidated for
being contrary to public policy and harmful to the government’s interests.
3. The Court interpreted “agreements involving either technical or financial assistance” in
Section 2, Article XII of the 1987 Constitution to cover service contracts, allowing
foreign corporations to provide comprehensive services for mineral resource exploration
and development. However, it emphasized that the State must retain full control and
supervision over these activities, similar to a board of directors overseeing a corporation.

Lidasan vs. COMELEC (G.R. No. L-28089, October 25, 1967)

Facts: Bara Lidasan, a resident, voter, and taxpayer of Parang, Cotabato, challenged the
constitutionality of RA No. 4790, which aims to create the Municipality of Dianaton in the
Province of Lanao del Sur. The Act included barrios that were in the Province of Cotabato,
specifically from the municipalities of Buldon and Parang. The COMELEC decided to
implement the Act for electoral purposes, despite including barrios from another province. This
led Lidasan to seek a writ of certiorari and prohibition, arguing the Act violated the constitutional
requirement that a bill must cover only one subject, clearly stated in its title. The case was
brought to the Supreme Court after COMELEC refused to suspend the Act, despite the
President’s recommendation for corrective legislation.

Issue:
1. Whether or not RA No. 4790 violated the constitutional requirement that no bill shall
embrace more than one subject, which must be expressed in the title of the bill.
2. Whether or not the petitioner has the standing to challenge the constitutionality of RA
No. 4790.

Ruling:
1. The Supreme Court declared RA No. 4790 null and void for violating the constitutional
requirement that a bill's title must reflect its single subject. The Court found the title
misleading, as it only mentioned the creation of the Municipality of Dianaton in Lanao
del Sur, without noting the transfer of barrios from Cotabato, which affected provincial
boundaries. The Court stressed that this important detail should have been disclosed in
the title and rejected the claim that the transfer was incidental, ruling it integral to the Act
and making the law unconstitutional.
2. The Court ruled that petitioner Bara Lidasan had standing to challenge the Act's
constitutionality, as his rights as a voter and taxpayer were affected. Being a qualified
voter and taxpayer in the area, Lidasan had a valid interest in ensuring the law governing
his electoral rights was constitutional, granting him the right to challenge the Act.