ICHONG v.

HERNANDEZ
G.R. No. L-7995 | May 31, 1957 | Labrador, J. | Parts of Statues > Title

Petitioner: LAO H. ICHONG, in his own behalf and in behalf of other alien
residents, corporations and partnerships adversely affected by RA No. 1180.

Respondent: JAIME HERNANDEZ, Secretary of Finance, and MARCELINO

SARMIENTO, City Treasurer of Manila

SUMMARY/FACTS:
The Legislature passed R.A. 1180 (An Act to Regulate the Retail Business). The
purpose of the Act was to prevent persons who are not citizens of the PH from
having a stranglehold upon the people’s economic life.

Lao Ichong, in his own behalf and behalf of other alien residents, corporations
and partnerships affected by the Act, filed an action to declare it
unconstitutional.

Petitioner attacks the constitutionality of the Act contending that the subject of
the Act is not expressed or comprehended in the title thereof.

In answer, the Solicitor-General and the Fiscal of the City of Manila contend
that the Act has only one subject embraced in the title.

DOCTRINE:
Section 21 (1) of Article VI: 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 RA 1180 is unconstitutional. – NO.

RULING: The Court finds the enactment of RA 1180 constitutional.
RATIO:
One purpose of the constitutional directive that the subject of a bill should be
embraced in its title is to apprise the legislators of the purposes, the nature
and scope of its provisions, and prevent the enactment into law of matters,
which have not received the notice, action and study of the legislators or of the
public.
The legislators took active interest in the discussion of the law, and a great
many of the persons affected by the prohibition in the law conducted a
campaign against its approval. It cannot be claimed, therefore, that the reasons
for declaring the law invalid ever existed.
What Section 21(1) of Article VI of the Constitution prohibits is duplicity, that
is, if its title completely fails to apprise the legislators or the public of the
nature, scope and consequences of the law or its operation