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

Decision 23 G.R. No. E-08557 Section 2 fixes the next election date and the recurring five-year interval. Clearly, the date of the next BSKE is not foreign to a law that fixes the term of office. As discussed, the power to determine the term includes the power to fix when it begins and when it ends. The title of Reptublic Act No. 12326 likewise states that it amends Republic Act No. 12232, a law that itself fixes both the term of office and the date of the BSKE. A reader of the title would reasonably expect that a change in the term would carry a corresponding change in the election cycle. The remaining provisions are similarly germane to the implementation of the new term structure. Section 4 establishes training and capacity-building programs expressly consistent with the new term; Section 5 prescribes how the transition is to be counted for purposes of term limits; Section 6 preserves accountability for incumbents during the transition; and Section 7 addresses the use of election appropriations in implementing the new schedule. Section 3, which provides for the appointment by city or municipal mayors of persons to fill vacancies in SK membership, presents:the more difficult question. It concerns the composition and continuity of the SK rather than the duration of the term itself. Nevertheless, the one-subject- one-title rule does not require every provision to prescribe the term directly. The question is: does the provision reasonably relate to organizing and maintaining the barangay and SK electoral structure under the Act, or is it unrelated to that subject? The Court should not uphold Section 3 solely because the law’s title includes “and for other purposes”; that phrase cannot save a provision unrelated to the title’s subject. The stronger justification is the provision’s connection to continuity in the SK’s composition during the law’s regulated term. In any case, even if this relationship were found insufficient, Section 3 could be severed under the separability clause in Section 8 of Republic Act No. 12326 without undermining the principal term-setting provisions. The validity of the entire statute should not automatically depend on a discrete ancillary provision’s validity if the statute can function coherently without it. : ce Neither was the effect of Republic Act No. 12326 on the November 2026 BSKE concealed. The legislative record cited by respondents shows that the relationship between the five-year term and the next election date was openly raised and debated, both in the. committee and on the floor, where the sponsor was interpellated on whether the measure complied with the 2023 Macalintal guidelines. Thus, the evils that the one subject-one title rule seeks to prevent are absent here. 3 Comment, pp. 47-48.