Tio vs.

Videogram Regulatory Board, 151 SCRA 208

Requirements as to bills: As to titles of bills

Facts: Petitioner Assails the constitutionality of Presidential Decree No.1987 entitled "An Act Creating the
Videogram Regulatory Board" with broad powers to regulate and supervise the videogram industry (hereinafter
briefly referred to as the BOARD).

On October 23, 1986, the Greater Manila Theaters Association, Integrated Movie Producers, Importers and
Distributors Association of the Philippines, and Philippine Motion Pictures Producers Association, hereinafter
collectively referred to as the Intervenors, were permitted by the Court to intervene in the case, over petitioner's
opposition, upon the allegations that intervention was necessary for the complete protection of their rights and
that their "survival and very existence is threatened by the unregulated proliferation of film piracy." The
Intervenors were thereafter allowed to file their Comment in Intervention.

Issue: Whether the Decree is unconstitutional having broad powers to regulate and supervise the videogram
industry

Ruling The Constitutional requirement that "every bill shall embrace only one subject which shall be expressed in
the title thereof" is sufficiently complied with if the title be comprehensive enough to include the general purpose
which a statute seeks to achieve. It is not necessary that the title express each and every end that the statute
wishes to accomplish. The requirement is satisfied if all the parts of the statute are related, and are germane to the
subject matter expressed in the title, or as long as they are not inconsistent with or foreign to the general subject
and title. An act having a single general subject, indicated in the title, may contain any number of provisions, no
matter how diverse they may be, so long as they are not inconsistent with or foreign to the general subject, and
may be considered in furtherance of such subject by providing for the method and means of carrying out the
general object." The rule also is that the constitutional requirement as to the title of a bill should not be so
narrowly construed as to cripple or impede the power of legislation. 4 It should be given a practical rather than
technical construction. Petitioner has not overcome the presumption of validity which attaches to a challenged
statute. We find no clear violation of the Constitution which would justify us in pronouncing Presidential Decree
No. 1987 as unconstitutional and void. WHEREFORE, the instant Petition is hereby dismissed. No costs. SO
ORDERED.
Lidasan vs. Comelec, 21 SCRA 479, 1967

Requirements as to bills: As to titles of bills

Facts: Republic Act 4790, which is entitled "An Act Creating the Municipality of Dianaton in the Province of Lanao
del Sur," but which includes barrios located in another province - Cotabato - to be spared from attack planted upon
the constitutional mandate that "No bill which may be enacted into law shall embrace more than one subject
which shall be expressed in the title of the bill

Issue: Whether or not Republic Act 4790 is null and void for embracing more than one subject which shall be
expressed in the title of the bill

Ruling The title - "An Act Creating the Municipality of Dianaton, in the Province of Lanao del Sur" -projects the
impression that solely the province of Lanao del Sur is affected by the creation of Dianaton. Not the slightest
intimation is there that communities in the adjacent province of Cotabato are incorporated in this new Lanao del
Sur town. The phrase "in the Province of Lanao del Sur," read without subtlety or contortion, makes the title
misleading, deceptive. For, the known fact is that the legislation has a two-pronged purpose combined in one
statute: (1) it creates the municipality of Dianaton purportedly from twenty-one barrios in the towns of Butig and
Balabagan, both in the province of Lanao del Sur; and (2) it also dismembers two municipalities in Cotabato, a
province different from Lanao del Sur. The baneful effect of the defective title here presented is not so difficult to
perceive. Such title did not inform the members of Congress as to the full impact of the law; it did not apprise the
people in the towns of Buldon and Parang in Cotabato and in the province of Cotabato itself that part of their
territory is being taken away from their towns and province and added to the adjacent Province of Lanao del Sur; it
kept the public in the dark as to what towns and provinces were actually affected by the bill. These are the
pressures which heavily weigh against the constitutionality of Republic Act 4790. For the reasons given, we vote to
declare Republic Act 4790 null and void
Cruz vs. Paras, 123 SCRA 106, 1994

Requirements as to bills: As to titles of bills

Facts: Ordinance 84 is worded as follows: "Section 1.— Title of Ordinance.— This Ordinance shall be known and
may be cited as the [Prohibition and Closure Ordinance] of Bocaue, Bulacan.

Section 2. — Definitions of Terms — (a) 'Night Club' …(b) 'Cabaret' or 'Dance Hall' … (c) 'Professional hostesses' or
'hospitality girls' … (d) 'Professional dancer' … (e) 'Operator' …

Issue: Whether or not the Municipal Council is authorized by law not only to regulate but to prohibit the
establishment, maintenance and operation of night clubs

Ruling: The decision now under review refers to Republic Act No. 938 as amended. It was originally enacted on
June 20, 1953. It is entitled: "AN ACT GRANTING MUNICIPAL OR CITY BOARDS AND COUNCILS THE POWER TO
REGULATE THE ESTABLISHMENT, MAINTENANCE AND OPERATION OF CERTAIN PLACES OF AMUSEMENT WITHIN
THEIR RESPECTIVE TERRITORIAL JURISDICTIONS.' Its first section insofar as pertinent reads: "The municipal or city
board or council of each chartered city shall have the power to regulate by ordinance the establishment,
maintenance and operation of night clubs, cabarets, dancing schools, pavilions, cockpits, bars, saloons, bowling
alleys, billiard pools, and other similar places of amusement within its territorial jurisdiction: ... "Then on May 21,
1954, the first section was amended to include not merely "the power to regulate, but likewise "Prohibit ...” The
title, however, remained the same. It is worded exactly as Republic Act No. 938. It is to be admitted that as thus
amended, if only the above portion of the Act were considered, a municipal council may go as far as to prohibit the
operation of night clubs. If that were all, then the appealed decision is not devoid of support in law. That is not all,
however. The title was not in any way altered. It was not changed one whit. The exact wording was followed. The
power granted remains that of regulation, not prohibition. There is thus support for the view advanced by
petitioners that to construe Republic Act No. 938 as allowing the prohibition of the operation of night clubs would
give rise to a constitutional question. The Constitution mandates: "Every bill shall embrace only one subject which
shall be expressed in the title thereof.” Since there is no dispute as the title limits the power to regulating, not
prohibiting, it would result in the statute being invalid if, as was done by the Municipality of Bocaue, the operation
of a night club was prohibited. There is a wide gap between the exercise of a regulatory power "to provide for the
health and safety, promote the prosperity, improve the morals, in the language of the Administrative Code, such
competence extending to all "the great public needs, to quote from Holmes, and to interdict any calling,
occupation, or enterprise. In accordance with the well-settled principle of constitutional construction that between
two possible interpretations by one of which it will be free from constitutional infirmity and by the other tainted by
such grave defect, the former is to be preferred. A construction that would save rather than one that would affix
the seal of doom certainly commends itself. WHEREFORE, the writ of certiorari is granted and the decision of the
lower court dated January 15, 1976 reversed, set aside, and nullied. Ordinance No. 84, Series of 1975 of the
Municipality of Bocaue is declared void and unconstitutional. The temporary restraining order issued by this Court
is hereby made permanent. No costs.
Tobias vs. Abalos, 239 SCRA 106, 1994

Requirements as to bills: As to titles of bills

Facts: Invoking their rights as taxpayers and as residents of Mandaluyong, herein petitioners assail the
constitutionality of Republic Act No. 7675, otherwise known as "An Act Converting the Municipality of
Mandaluyong into a Highly Urbanized City to be known as the City of Mandaluyong."

Petitioners now come before this Court, contending that R.A. No. 7675, specifically Article VIII, Section 49 thereof,
is unconstitutional for being violative of the Constitution.

Article VIII, Section 49 of R.A. No. 7675 provides:

"As a highly-urbanized city, the City of Mandaluyong shall have its own legislative district with the first
representative to be elected in the next national elections after the passage of this Act. The remainder of the
former legislative district of San Juan/Mandaluyong shall become the new legislative district of San Juan with its
first representative to be elected at the same election."
Petitioner's first objection to the aforequoted provision of R.A. No. 7675 is that it contravenes the "one subject-
one bill" rule, as enunciated in Article VI, Section 26 (1) of the Constitution, to wit:

"Sec. 26 (1). Every bill passed by the Congress shall embrace only one subject which shall be expressed in the title
thereof."

Petitioners allege that the inclusion of the assailed Section 49 in the subject law resulted in the latter embracing
two principal subjects, namely: (1) the conversion of Mandaluyong into a highly urbanized city; and (2) the division
of the congressional district of San Juan/Mandaluyong into two separate districts. Petitioners contend that the
second aforestated subject is not germane to the subject matter of R.A. No. 7675 since the said law treats of the
conversion of Mandaluyong into a highly urbanized city, as expressed in the title of the law. Therefore, since
Section 49 treats of a subject distinct from that stated in the title of the law, the "one subject-one bill" rule has not
been complied with.

Issue: Whether or not Republic Act No. 7675, otherwise known as "An Act Converting the Municipality of
Mandaluyong into a Highly Urbanized City to be known as the City of Mandaluyong is constitutional

Ruling: Contrary to petitioners' assertion, the creation of a separate congressional district for Mandaluyong is not a
subject separate and distinct from the subject of its conversion into a highly urbanized city but is a natural and
logical consequence of its conversion into a highly urbanized city. Verily, the title of R.A. No. 7675 "An Act
Converting the Municipality of Mandaluyong into a Highly Urbanized City of Mandaluyong" necessarily includes
and contemplates the subject treated under Section 49 regarding the creation of a separate congressional district
for Mandaluyong. Moreover, a liberal construction of the "one title-one subject" rule has been invariably adopted
by this court so as not to cripple or impede legislation. WHEREFORE, the petition is hereby DISMISSED for lack of
merit. SO ORDERED.
Demetria v. Alba, 148 SCRA 208, 1987

Requirements as to certain laws: Appropriation laws

Facts: Petitioner assailed the constitutionality of the first paragraph of Section 44 of Presidential Decree No. 1177,
otherwise known as the "Budget Reform Decree of 1977."

"The President shall have the authority to transfer any fund, appropriated for the different departments, bureaus,
offices and agencies of the Executive Department, which are included in the General Appropriations Act, to any
program, project or activity of any department, bureau, or office included in the General Appropriations Act or
approved after its enactment."

On the other hand, the constitutional provision under consideration reads as follows:

"Sec. 16[5]. No law shall be passed authorizing any transfer of appropriations, however, the President, the Prime
Minister, the Speaker, the Chief Justice of the Supreme Court, and the heads of constitutional commissions may by
law be authorized to augment any item in the general appropriations law for their respective offices from savings
in other items of their respective appropriations."

Issue: Whether or not Paragraph 1 of Section 44 of Presidential Decree No. 1177 is unconstitutional

Ruling: Paragraph 1 of Section 44 of P.D. No. 1177 unduly overextends the privilege granted under said Section
16[5]. It empowers the President to indiscriminately transfer funds from one department, bureau, office or agency
of the Executive Department to any program, project or activity of any department, bureau or office included in
the General Appropriations Act or approved after its enactment, without regard as to whether or not the funds to
be transferred are actually savings in the item from which the same are to be taken, or whether or not the transfer
is for the purpose of augmenting the item to which said transfer is to be made. It does not only completely
disregard the standards set in the fundamental law, thereby amounting to an undue delegation of legislative
powers, but likewise goes beyond the tenor thereof. Indeed, such constitutional infirmities render the provision in
question null and void. WHEREFORE, the instant petition is granted. Paragraph 1 of Section 44 of Presidential
Decree No. 1177 is hereby declared null and void for being unconstitutional. SO ORDERED.