Philippine Constitution Association v. Gimenez, G.R. No.

L-23326, December 18, 1965

FACTS:

The petitioners Philconsa assail the validity of RA 3836 and filed this Petition for Prohibition with
Preliminary Injunction to restrain the Auditor General of the Philippines and the disbursing officers of
both Houses of Congress from passing in audit the payment to any former member of the Congress of
retirement and vacation gratuities. RA 3836 is assailed on the grounds that: (a) the provision for the
retirement benefits of the members of Congress is not expressed in the title of the bill; (b) the provision
on retirement gratuity is an attempt to circumvent the Constitutional prohibition on increase of salaries
during their term of office; (c) the provision constitutes a “selfish class legislation” because it allows
members and officers of Congress to retire after twelve (12) years of service, the retirement benefits not
refundable in case of re-election or re-instatement; (d) the provision on vacation and sick leave
commutable at the highest rate received manifest an attempt to increase their compensation a violation
of the Constitution.

ISSUES:

(1) Whether or not petitioner Philconsa has a standing to institute this action.

(2) Whether or not RA 3836 falls within the prohibition embodied in Article VI, Section 14 of the
Constitution.

(3) Whether or not RA 3836 violates the equal protection clause.

(4) Whether or not the title of RA 3836 is germane to the subject matter expressed in the act.

RULING:

(1) Yes. Philconsa, a non-profit, civic organization composed of several leaders from all walks of life
whose main objective is to uphold the principles of the Constitution, has legal standing to institute the
action as substantial taxpayers in preventing the illegal expenditure of public funds.

(2) Yes. The provisions of RA 3836 falls squarely within the prohibition set forth in Article VI, Section 14
of the Constitution.

(3) Yes. The assailed feature in RA 3836 are patently discriminatory and therefore violate the equal
protection clause of the Constitution. All government officers and employees are given only one
retirement benefit irrespective of their length of service.

(4) No. The title of RA 3836 is void and is not germane to the subject matter in violation of Paragraph 1,
Section 21, Article VI of the Constitution which provides 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. RA 3836 is declared null
and void with respect to the retirement of Members of Congress and the elected officials thereof, as
being unsconstituional.
Giron v. COMELEC, G.R. No. 188179, January 22, 2013

FACTS:

Petitioner Giron asserts that the insertion of Sections 12 and 14 in the Fair Election Act violates Section
26(1), Article VI of the 1987 Constitution, which specifically requires: "Every bill passed by the Congress
shall embrace only one subject which shall be expressed in the title thereof." Petitioner avers that these
provisions are unrelated to the main subject of the Fair Election Act: the lifting of the political ad ban.
Section 12 refers to the treatment of the votes cast for substituted candidates after the official ballots
have been printed, while Section 14 pertains to the repeal of Section 67 (Candidates holding elective
office) of Batas Pambansa Blg. 881, otherwise known as the Omnibus Election Code. Section 67 of this
law concerns the ipso facto resignation of elective officials immediately after they file their respective
certificates of candidacy for an office other than that which they are currently holding in a permanent
capacity.

ISSUE:

Whether or not the inclusion of Sections 12 and 14 in the Fair Election Act violates Section 26(1), Article
VI of the 1987 Constitution, or the "one subject-one title" rule.

RULING:

It is a well-settled rule that courts are to adopt a liberal interpretation in favor of the constitutionality of
a legislation, as Congress is deemed to have enacted a valid, sensible, and just law. Because of this
strong presumption, the one who asserts the invalidity of a law has to prove that there is a clear,
unmistakable, and unequivocal breach of the Constitution; otherwise, the petition must fail.

The Court find that petitioner and petitioners-in-intervention were unable to present a compelling
reason that would surpass the strong presumption of validity and constitutionality in favor of the Fair
Election Act.

Constitutional provisions relating to the subject matter and titles of statutes should not be so narrowly
construed as to cripple or impede the power of legislation. The requirement that the subject of an act
shall be expressed in its title should receive a reasonable and not a technical construction. It is sufficient
if the title be comprehensive enough reasonably to include the general object which a statute seeks to
effect, without expressing each and every end and means necessary or convenient for the accomplishing
of that object. Mere details need not be set forth. The title need not be an abstract or index of the Act.

Moreover, the avowed 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 and the public.

Astorga v. Villegas, G.R. No. L-23475, April 30, 1974

On March 30, 1964 House Bill No. 9266, a bill of local application, was filed in the House of
Representatives. It was there passed on third reading without amendments on April 21, 1964. Forthwith
the bill was sent to the Senate for its concurrence. It was referred to the Senate Committee on Provinces
and Municipal Governments and Cities headed by Senator Gerardo M. Roxas. The committee favorably
recommended approval with a minor amendment, suggested by Senator Roxas, that instead of the City
Engineer it be the President Protempore of the Municipal Board who should succeed the Vice-Mayor in
case of the latter's incapacity to act as Mayor.

When the bill was discussed on the floor of the Senate on second reading on May 20, 1964, substantial
amendments to Section 11 were introduced by Senator Arturo Tolentino. Those amendments were
approved in toto by the Senate. The amendment recommended by Senator Roxas does not appear in
the journal of the Senate proceedings as having been acted upon.

On May 21, 1964 the Secretary of the Senate sent a letter to the House of Representatives that House
Bill No. 9266 had been passed by the Senate on May 20, 1964 "with amendments." Attached to the
letter was a certification of the amendment, which was the one recommended by Senator Roxas and not
the Tolentino amendments which were the ones actually approved by the Senate. The House of
Representatives thereafter signified its approval of House Bill No. 9266 as sent back to it, and copies
thereof were caused to be printed. The printed copies were then certified and attested by the Secretary
of the House of Representatives, the Speaker of the House of Representatives, the Secretary of the
Senate and the Senate President. On June 16, 1964 the Secretary of the House transmitted four printed
copies of the bill to the President of the Philippines, who affixed his signatures thereto by way of
approval on June 18, 1964. The bill thereupon became Republic Act No. 4065.

The furor over the Act which ensued as a result of the public denunciation mounted by respondent City
Mayor drew immediate reaction from Senator Tolentino, who on July 5, 1964 issued a press statement
that the enrolled copy of House Bill No. 9266 signed into law by the President of the Philippines was a
wrong version of the bill actually passed by the Senate because it did not embody the amendments
introduced by him and approved on the Senate floor. As a consequence the Senate President, through
the Secretary of the Senate, addressed a letter dated July 11, 1964 to the President of the Philippines,
explaining that the enrolled copy of House Bill No. 9266 signed by the secretaries of both Houses as well
as by the presiding officers thereof was not the bill duly approved by Congress and that he considered
his signature on the enrolled bill as invalid and of no effect. A subsequent letter dated July 21, 1964
made the further clarification that the invalidation by the Senate President of his signature meant that
the bill on which his signature appeared had never been approved by the Senate and therefore the fact
that he and the Senate Secretary had signed it did not make the bill a valid enactment.

ISSUE:
Whether or not a resolution of both Houses of Congress proposing an amendment to the (1935)
Constitution to be appended as an ordinance thereto (the so-called parity rights provision) had been
passed by "a vote of three-fourths of all the members of the Senate and of the House of
Representatives" pursuant to Article XV of the Constitution.

RULING:

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. 

This Court is merely asked to inquire whether the text of House Bill No. 9266 signed by the Chief
Executive was the same text passed by both Houses of Congress. Under the specific facts and
circumstances of this case, this Court can do this and resort to the Senate journal for the purpose. The
journal discloses that substantial and lengthy amendments were introduced on the floor and approved
by the Senate but were not incorporated in the printed text sent to the President and signed by him.
This Court is not asked to incorporate such amendments into the alleged law, which admittedly is a risky
undertaking, 13 but to declare that the bill was not duly enacted and therefore did not become law. This
We do, as indeed both the President of the Senate and the Chief Executive did, when they withdrew
their signatures therein. In the face of the manifest error committed and subsequently rectified by the
President of the Senate and by the Chief Executive, for this Court to perpetuate that error by
disregarding such rectification and holding that the erroneous bill has become law would be to sacrifice
truth to fiction and bring about mischievous consequences not intended by the law-making body.

In view of the foregoing considerations, the petition is denied and the so-called Republic Act No. 4065
entitled "AN ACT DEFINING THE POWERS, RIGHTS AND DUTIES OF THE VICE-MAYOR OF THE CITY OF
MANILA, FURTHER AMENDING FOR THE PURPOSE SECTIONS TEN AND ELEVEN OF REPUBLIC ACT
NUMBERED FOUR HUNDRED NINE, AS AMENDED, OTHERWISE KNOWN AS THE REVISED CHARTER OF
THE CITY OF MANILA" is declared not to have been duly enacted and therefore did not become law. The
temporary restraining order dated April 28, 1965 is hereby made permanent. No pronouncement as to
costs.

PHILJA v. Prado, G.R. No. 105371, November 11, 1993, 227 SCRA 203

FACTS:
The main target of this petition is Section 35 of R.A. No. 7354 as implemented by the Philippine Postal
Corporation through its Circular No. 9228. These measures withdraw the franking privilege from the
Supreme Court, the Court of Appeals, the Regional Trial Courts, the Metropolitan Trial Courts, the
Municipal Trial Courts, and the Land Registration Commission and its Registers of Deeds, along with
certain other government offices. The petitioners are members of the lower courts who feel that their
official functions as judges will be prejudiced by the above-named measures. 

The petition assails the constitutionality of R.A. No. 7354 on the grounds that: (1) its title embraces more
than one subject and does not express its purposes; (2) it did not pass the required readings in both
Houses of Congress and printed copies of the bill in its final form were not distributed among the
members before its passage; and (3) it is discriminatory and encroaches on the independence of the
Judiciary.

ISSUE:

Whether or not R.A. No.7354 is unconstitutional based on the three (3) grounds.

RULING:

(1) The petitioners' contention is untenable. The title of the bill is not required to be an index to the
body of the act, or to be as comprehensive as to cover every single detail of the measure. It has been
held that if the title fairly indicates the general subject, and reasonably covers all the provisions of the
act, and is not calculated to mislead the legislature or the people, there is sufficient compliance with the
constitutional requirement. The reason is that where a statute repeals a former law, such repeal is the
effect and not the subject of the statute; and it is the subject, not the effect of a law, which is required
to be briefly expressed in its title.

(2) This argument is unacceptable. While a conference committee is the mechanism for compromising
differences between the Senate and the House, it is not limited in itsjurisdiction to this question. It may
propose an entirely new provision. The court also added that the said bill in question was duly approved
by the Senate and the House of Representatives. It was enrolled with its certification by Senate
President and Speaker of the House of Representatives. It was then presented to and approved by the
President. Under the doctrine of separation powers, the Court may not inquire beyond the certification
of the approval of a bill from the presiding officers of Congress. An enrolled bill is conclusive upon the
Judiciary. The court therefore declined to look into the petitioners' charges. Both the enrolled bill and
the legislative journals certify that the measure was duly enacted. The court is bound by such official
assurances from acoordinate department of the government.

(3) Yes, the clause denies the Judiciary the equal protection of the laws guaranteed for allpersons or
things similarly situated. The distinction made by the law is superficial. It is not based on substantial
distinctions that make real differences between the Judiciary and the grantees of the franking privilege.
If the problem of the respondents is the loss of revenues from the franking privilege, the remedy, it
seems to us, is to withdraw it al together from all agencies of government, including those who do not
need it.

Accordingly, the petition is partially granted and Section 35 of R.A. No. 7354 is declared
unconstitutional.