Philippine Constitution Association., Inc., (PHILCONSA) vs. Pedro M.

Gimenez
G.R. No. L-23326, REGALA, 1965-12-18

Legal Keywords/Doctrine:
Retirement benefits for members of Congress, as provided in Republic Act No.
3836, violate the prohibition on salary increases during their term, the equal
protection clause, and the requirement that the title of a bill should only have one
subject.

Dispositive Portion: IN VIEW OF THE FOREGOING CONSIDERATIONS. Republic Act No.

3836 is hereby declared null and void, in so far as it refers to the retirement of Members of Congress and
the elected officials thereof, as being' unconstitutional. The restraining order issued in our resolution on
December 6, 1965 is hereby made permanent. No costs.

Contention:
The contentions of both parties in the case are as follows:

1. Petitioner's contention: The petitioner argues that Republic Act No. 3836, which
provides retirement benefits to members of Congress, violates the prohibition on
salary increases during their term, the equal protection clause, and the
requirement that the title of a bill should only have one subject. They also argue
that certain indispensable parties were not included in the petition and that the
petitioner has no standing to institute the suit.

2. Respondent's contention: The respondent argues that Republic Act No. 3836 is
constitutional and does not violate the prohibition on salary increases during
their term, the equal protection clause, or the requirement of a single subject in the
title of a bill. They also argue that the payment of retirement benefits is not an
indirect scheme to increase their salary and that the retirement benefits provided by
the law are not discriminatory.

Facts:
The constitutionality of Republic Act No. 3836, which provides retirement benefits
to members of Congress. The petitioner argues that the law violates Section 14,
Article VI of the Constitution, which states that the compensation of senators and
members of the House of Representatives shall not be increased until after the
expiration of their full term. The petitioner also argues that the law violates the
equal protection clause of the Constitution, as it grants retirement benefits only to
members of Congress and not to other elected officials. Additionally, the petitioner
argues that the title of the law does not adequately express its subject matter.

Issue/s:
1. Whether or not Republic Act No. 3836 violates Section 14, Article VI of the
Constitution.

2. Whether or not the law violates the equal protection clause of the
Constitution.

3. Whether or not the title of Republic Act No. 3836 is germane to the subject
matter expressed in the act.

Ruling:
The Supreme Court ruled in favor of the petitioner and declared Republic Act No.
3836 unconstitutional.

Ratio:
The Court held that taxpayers have sufficient interest in preventing the illegal
expenditure of public funds and may question the constitutionality of statutes
requiring expenditures of public money. Therefore, the contention that the
petitioner lacks standing to challenge the constitutionality of the law is
untenable.

The Court found that Republic Act No. 3836 violates Section 14, Article VI of the
Constitution. The Constitution imposes limitations and prohibitions on members of
Congress, including the prohibition on increasing their compensation during their
term. The retirement benefits provided by the law constitute an increase in
compensation and are therefore prohibited.
The Court also found that the law violates the equal protection clause of the
Constitution. The law grants retirement benefits only to members of Congress and
not to other elected officials, which is an arbitrary and unreasonable classification.
Additionally, the law discriminates against other government employees who are
required to serve a longer period of time before being eligible for retirement
benefits.

The Court further held that the title of Republic Act No. 3836 is not germane
to the subject matter expressed in the act. The title suggests that the law is about
the retirement of members of Congress and elected officials, but it also includes
provisions on vacation and sick leave benefits. These provisions are not related
to the retirement of members of Congress and elected officials and therefore
violate the constitutional requirement that the subject of an act should be expressed
in its title.