Datu Sinsuat v. Ahod Ebrahim

 

Datu Sinsuat v. Ahod Ebrahim

G.R. No. 271741/271972

August 20, 2024

 

FACTS:

                On July 21, 2018, the Bangsamoro Organic Law was approved. Subsequently, RA 11550 or the Charter of the Provinces of Maguindanao del Norte and Maguindanao del Sur, was enacted into law. The Municipality of Datu Odin Sinsuat was designated as the capital town and seat of government of Maguindanao del Norte. The BAA 49 was enacted or the Bangsamoro Local Governance Code of 2023 (Bangsamoro LGC). The BAA 53, 54 and 55 created the Municipality of Nuling, Municipality of Datu Sinsuat Balabaran and Municipality of Sheik Abas Hamza respectively. The petition in G.R. No. 271741 assailing BAAs 54 and 55 was filed on February 15, 2024, while the petition in G.R. No. 271972 challenging BAA 53 was filed on February 29, 2024.

ISSUE:

                Whether or not BAAs 53, 54, and 55 violate Article VI, Section 26(1) of the 1987 Constitution.

HELD:

                No. The requirement of Article VI, Section 26(1) of the 1987 Constitution must be given a meaning which is reasonable and not unduly technical. In Alalayan v. National Power Corporation, the Court ruled that it is sufficient for a title to be comprehensive enough to reasonably include the general object of the statute: It must be deemed sufficient that the title be comprehensive enough reasonably to include the general object which the statute seeks to effect without expressing each and every end and means necessary for its accomplishment. Thus, mere details need not be set forth. The legislature is not required to make the title of the act a complete index of its contents. The provision merely calls for all parts of an act relating to its subject finding expression in its title. It suffices if the title should serve the purpose of the constitutional demand that it inform the legislators, the persons interested in the subject of the bill, and the public, of the nature, scope and consequences of the proposed law and its operations. And this, to lead them to inquire into the body of the bill, study and discuss the same, take appropriate action thereon, and, thus, prevent surprise or fraud upon the legislators.

                Here, it is clear that the title of BAA 53 sufficiently informs the public of the intention to create a new municipality within the province of Maguindanao del Norte. This should serve as adequate impetus for interested persons to inquire into the body of the law to determine which barangays in the province of Maguindanao del Norte would now constitute the Municipality of Nuling, and to take appropriate action thereon – as indeed, the petitioners in this case have. We apply the same reasoning to BAAs 54 and 55.