Parts of a Statute

1) How requirement of title construed

2) Effect of insufficiency of title

5. Article 2 of Republic Act No. 972 is not embraced in the title of the law, contrary to what the Constitution enjoins, and being
inseparable from the provisions of article 1, the entire law is void.

Our conclusion may be epitomized as follows: For more than six centuries prior to the adoption of our Constitution, the courts of
England, concededly subordinate to Parliament since the Revolution of 1688, had exercise the right of determining who should be
admitted to the practice of law, which, as was said in Matter of the Sergeant's at Law, 6 Bingham's New Cases 235, "constitutes the
most solid of all titles." If the courts and judicial power be regarded as an entity, the power to determine who should be admitted to
practice law is a constituent element of that entity. It may be difficult to isolate that element and say with assurance that it is either
a part of the inherent power of the court, or an essential element of the judicial power exercised by the court, but that it is a power
belonging to the judicial entity and made of not only a sovereign institution, but made of it a separate independent, and coordinate
branch of the government. They took this institution along with the power traditionally exercise to determine who should constitute
its attorney at law. There is no express provision in the Constitution which indicates an intent that this traditional power of the
judicial department should in any manner be subject to legislative control. Perhaps the dominant thought of the framers of our
constitution was to make the three great departments of government separate and independent of one another. The idea that the
Legislature might embarrass the judicial department by prescribing inadequate qualifications for attorneys at law is inconsistent with
the dominant purpose of making the judicial independent of the legislative department, and such a purpose should not be inferred
in the absence of express constitutional provisions. While the legislature may legislate with respect to the qualifications of attorneys,
but is incidental merely to its general and unquestioned power to protect the public interest. When it does legislate a fixing a
standard of qualifications required of attorneys at law in order that public interests may be protected, such qualifications do not
constitute only a minimum standard and limit the class from which the court must make its selection. Such legislative qualifications
do not constitute the ultimate qualifications beyond which the court cannot go in fixing additional qualifications deemed necessary
by the course of the proper administration of judicial functions. There is no legislative power to compel courts to admit to their bars
persons deemed by them unfit to exercise the prerogatives of an attorney at law. (p. 450)

3) Declaring a law unconstitutional vested with the courts

The settled rule of statutory construction is that repeals by implication are not favored. [20] R.A. No. 7202 cannot be deemed to
have repealed P.D. No. 579. In addition, the power to declare a law unconstitutional does not lie with the legislature, but with
the courts.[21] Assuming arguendo that R.A. No. 7202 did indeed repeal P.D. No. 579, said repeal is not a legislative declaration
finding the earlier law unconstitutional.

4) Enrolled bill
a) Fariñas v executive sec
b) Astorga v. Villegas

Appeal by the Commissioner

In the first assignment of error, the Commissioner contends that the first proviso in Section 5 of Republic Act No. 1435 is
unconstitutional. In claiming the unconstitutionality of the aforesaid section, the Commissioner anchored its argument on
Article VI, Section 21(l) of the 1935 Constitution which provides:

No bill which may be enacted into a law shall embrace more than one subject which shall be expressed in the title of the
bill be

The title of R.A. No. 1435 is "An Act to Provide Means for Increasing The Highway Special Fund." The Commissioner
contends that the subject of R.A. No. 1435 was to increase Highway Special Fund. However, Section 5 of, the Act deals
with another subject which is the partial exemption of miners and loggers. And tills partial exemption on which the
Company based its claim for refund is clearly not expressed in the title of the aforesaid Act. More importantly, Section 5
provides for a decrease rather than an increase of the Highway Special Fund.