Romulo B. Macalintal v. Office of the President, et al. — Decision — Official PDF

Decision 22 G.R. No. E-08557 Indeed, the law abhors a vacuum in public offices, and courts generally indulge in the strong presumption against a legislative intent to create, by statute, a condition which may result in an executive or administrative office becoming, for any period of time, wholly vacant or unoccupied by one lawfully authorized to exercise its functions. This is founded on obvious considerations of public policy, for the principle-of holdover is specifically intended to prevent public convenience from suffering because of a vacancy and to avoid a hiatus in the performance of government functions.*° VII. Republic Act No. 12326 does not violate the one-subject-one title rule Article VI, Section 26(1} of the Constitution provides that “[e]very bill passed by the Congress shall embrace only one subject which shall be expressed in the title thereof.” The Court has consistently given this requirement a liberal rather than a technical construction. The title need not mirror, fully index, or catalogue all the contents and minute details of the law; it suffices that the title is compreliensive enough to include the general object that the statute seeks to implement.*! The provision is “aimed against the evils of the so-called omnibus bills and log-rolling legislation as well as surreptitious and/or unconsidered encroaches.”°* The controlling-question is whether each challenged provision bears a fair and reasonable relationship to the statute’s general subject. In 2025 Macalintal, the Court held that Republic Act No. 12232’s single subject is the prescription of a new term for barangay and SK officials, and that “[t]he supposedly separate subjects contained in its provisions are actually necessary components of establishing this new, four-year term structure.” Here, the principal subject of Republic Act No. 12326 is the establishment of a five-year term and the corresponding electoral cycle for barangay and SK officials. The provisions of Republic Act No. 12326 must be examined according te whether they are germane or reasonably incidental! to the implementation of that term structure. The title’s reference to “other purposes” does not dispense with this inquiry; neither, however, does the Constitution require every section to prescribe the term directly. Upon careful examination cf Republic Act No. 12326, the Court is convinced that each provision. bears a direct or reasonably incidental relationship to the establishment and implementation of the new term structure. Indeed, Sections 2, 3, 4 and 6 of Republic Act No. 12326 are not riders. %° 364 Phil. 890, 903 (1999) [Per J. Beitosili 5! Farifius v. Executive Secretary, 463 52g. vision}. (Citations omitted) ) [Per J. Callejo, Sr., Zn Banc].