Title of the Bill
Code of Civil Procedure, as amended by Act No. 2210,
Bara Lidasan V COMELEC
Petitioner relies upon the constitutional requirement
aforestated, that "[n]o bill which may be enacted into
law shall embrace more than one subject which shall be
expressed in the title of the bill."
It may be well to state, right at the outset, that the
constitutional provision contains dual limitations upon
legislative power. First. Congress is to refrain from
conglomeration, under one statute, of heterogeneous
subjects. Second. The title of the bill is to be couched in
a language sufficient to notify the legislators and the
public and those concerned of the import of the single
subject thereof.
In our task of ascertaining whether or not the title of a
statute conforms with the constitutional requirement,
the following, we believe, may be taken as guidelines:
The test of the sufficiency of a title is whether or not it is
misleading; and, which technical accuracy is not
essential, and the subject need not be stated in express
terms where it is clearly inferable from the details set
forth, a title which is so uncertain that the average
person reading it would not be informed of the purpose
of the enactment or put on inquiry as to its contents, or
which is misleading, either in referring to or indicating
one subject where another or different one is really
embraced in the act, or in omitting any expression or
indication of the real subject or scope of the act, is bad.
In determining sufficiency of particular title its substance
rather than its form should be considered, and the
purpose of the constitutional requirement, of giving
notice to all persons interested, should be kept in mind
by the court.
Giron V COMELEC
The proscription under Section 26(1), Article VI of the
Constitution is aimed against the evils of the so-called
omnibus bills and log-rolling legislation as well as
surreptitious and/or unconsidered encroaches. The
provision merely calls for all parts of an act relating to its
subject finding expression in its title.
Enrolled Bill Theory
Mabanag V Lopez Vito
It will be seen upon examination of section 313 of the
that, roughly, it provides two methods of proving
legislative proceedings: (1) by the journals, or by
published statutes or resolutions, or by copies certified
by the clerk or secretary or printed by their order; and
(2) in case of acts of the Legislature, by a copy signed by
the presiding officers and secretaries thereof, which
shall be conclusive proof of the provisions of such Acts
and of the due enactment thereof.
Journal Entry Rule
Astorga V Villegas
It may be noted that the enrolled bill theory is based
mainly on "the respect due to coequal and independent
departments," which requires the judicial department
"to accept, as having passed Congress, all bills
authenticated in the manner stated." Thus it has also
been stated in other cases that if the attestation is
absent and the same is not required for the validity of a
statute, the courts may resort to the journals and other
records of Congress for proof of its due enactment.
But the said Constitution does contain the following
provisions:
Sec. 10 (4). "Each House shall keep a Journal of its
proceedings, and from time to time publish the same,
excepting such parts as may in its judgment require
secrecy; and the yeas and nays on any question shall, at
the request of one-fifth of the Members present, be
entered in the Journal."
Sec. 21 (2). "No bill shall be passed by either House
unless it shall have been printed and copies thereof in its
final form furnished its Members at least three calendar
days prior to its passage, except when the President
shall have certified to the necessity of its immediate
enactment. Upon the last reading of a bill no
amendment thereof shall be allowed, and the question
upon its passage shall be taken immediately thereafter,
and the yeas and nays entered on the Journal."