Format

Topic of the Case:

Petitioner/Plaintiff:
Responded/Defendant:
Other parties involved

GR NUMBER
TITLE
PONENTE

Facts:
Issues:
Held:
Ratio:

1st case
Topic of the Case: Jurisdiction over 16 to 21 years old
Petitioner: People of the Philippines
Respondent: ​HON. JUDGE MERICIA B. PALMA and ROMULO INTIA Y MORADA

G.R. No. L-44113

TEEHANKEE, ​J​.:

FACTS:
*The Court is resolving an issue about a conflict of jurisdiction between the City Court of Naga (presided by
respondent judge) and the Juvenile and Domestic Relations Courts for Camarines Sur - over who should handle
criminal cases if the accused is 16 but under 21 years of age.

*An accused, Romulo Intia y Morada, 17 years of age, was charged on February 10, 1976 by the Naga City fiscal's
office with vagrancy (Article 202, RPC) in respondent judge's court (Judge Palma).
*The respondent judge dismissed the case on the ground that her court "has no jurisdiction to continue over the
case" without prejudice to the refiling thereof in the Juvenile Court.
*Meanwhile, the prosecution shares the view of the Camarines Sur Juvenile and Domestic Relations Court (JDRC)
that jurisdiction over 16-year olds up to under 21 years remains with the regular courts and has not been by
implication transferred to the Juvenile Court.

ISSUE:
1. W/N the City Court of Naga, subject to R.A. 6591 and P.D. 603 has the jurisdiction over criminal cases involving
accused who are 16 to 21 years old.

DOCTRINE:
*P.D. 603 (Child and Youth Welfare Code) - youthful offenders of 9 years old to 21 years old upon commission of
crime does not transfer jurisdiction of cases from the Regular Courts (City Court) to the Juvenile Courts.
*R.A. 6591 created Camarines Sur limited jurisdiction over “criminal cases wherien the accused is below 16 years
old upon the commission of offense”

Defense ng Judge: Since 17 years old palang yung accused, jurisdiction yan ng JDRC, not the Regular Court, given
na covered naman siya ng P.D. 603 (9 to 21 y.o), at ina-mend naman na daw niya yung R.A. 6591.

Defense ng Prosecutor: A general law cannot repeal a special law by mere implication. ​The repeal must be express
and specific. The JDRC of Camarines Sur, is a court of limited jurisdiction and adding accused persons who are 16
to 21 years of age must appear in express terms.
HELD:
1. Petition sustained, the City Court of Naga has the jurisdiction over criminal cases (16 to 21 years old).

RULING: ​The Court sustains the petition on the following grounds:

1. R.A. 6591 which took effect on 1972 created the Camarines Sur limited jurisdiction over “criminal cases wherein
the accused is below 16 years old upon the commission of the offense”.

*The subsequent issuance of P.D. 603 “Child and Youth Welfare Code” took effect in 1975 and defines in Article
189 a youthful offender as “one who is over 9 y/o but below 21 y/o” does not transfer jurisdiction over criminal
cases involving accused who are 16 to 21 years old from the Regular Courts to the Juvenile Courts.

2. P.D. 603 is a general law concerning the welfare of the child and youth all over the country, while R.A. 6591 that
confers jurisdiction on the JDRC for Camarines Sur is a special law, classifying expressly that it can try in criminal
cases involving offenders who are under 16 years of a age.

*The respondent judge defends that "together, the two laws, the latter amending the former, confer jurisdiction on
youthful offenders from 16 to 21 years of age upon the JDRC of Camarines Sur and remove the same from the City
Court." However, Jurisdiction is conferred by law and there is nothing in either R.A. 6591 or P.D. 603 and would
not sustain the respondent judge’s defense.

*​A general law cannot repeal a special law by mere implication. ​The repeal must be express and specific.
Furthermore, the JDRC of Camarines Sur is a court of limited jurisdiction and the additional jurisdiction to include
accused persons who are 16 to 21 years of age must appear in express terms.

3. If the intent and purpose of P.D. 603 is to remove from the City Court the jurisdiction over youthful accused who
are 16 but below 21 years of age and transfer the same to the Juvenile Court, it would have expressly so provided for
repeal of the corresponding provision.

*P.D. No. 798, which went into effect on September 11, 1975, strengthened the prosecution's stand that jurisdiction
over accused who are 16-years old up to 21 years remains with the regular courts while the Juvenile Courts retain
their limited jurisdiction only over those under 16 years.
Content of P.D. 798​: Thus, P. D. No. 798, "Authorizing the Confinement in Rehabilitation Centers or
Reformatories of Truants and Youths out of School for No Legitimate Reason," provides that the
application for confinement of out of school youths shall be filed with the proper court of First Instance of
the province or city unless it is ​under 1​ 6 years of age, the application shall be filed with the Juvenile Court
where such a court has been established.

4. The Solicitor General has properly acknowledged the role and jurisdiction of Juvenile Courts are matters of policy
and wisdom, however, and in the face of the clear letter of the law, the special jurisdiction granted to juvenile Courts
which is limited to cases where the accused is under 16 years of age cannot be expanded by judicial fiat.

5. Di na kailangan yung fifth na sinasabi

ACCORDINGLY, the dismissal orders of respondent judge dated March 6, 1976 and April 1, 1976 are set aside.
The case filed with respondent judge's court is ordered reinstated for prompt trial and determination on the merits. In
the public interest this decision resolving the jurisdictional conflict shall be immediately executory upon
promulgation.
2ND CASE

This is an appeal from a decision of the Court of First Instance of Abra dismissing a petition for ​certiorari​.
G.R. No. L-1276 April 30, 1948
ROSARIO VALERA, assisted by her husband, Juan Valera,​ petitioner,
vs.
MARIANO TUASON, Jr., Justice of the Peace of Lagayan, Abra, MANUEL TULLAS ET AL.,
respondents-appellees.
THE PROVINCIAL FISCAL, ​intervenor-appellee.
TUASON, ​J.​:

FACTS:
*Judge Federico Paredes, justice of the peace of court of Lagayan, was disqualified by reason of relationship to one
of the parties in a complaint for forcible entry.
*To try the case, Judge Paredes transferred it to the justice of the peace of La Paz, the nearest municipality to
Lagayan. La Paz justice of the peace, over the objection of the attorney for the defendants, proceeded with the trial.
He gave judgment for the plaintiff, and brought the decision over the case back to the justice of the peace of
Lagayan.
*In the meantime, a new justice of the peace had been appointed for Lagayan — Mariano B. Tuason, one of the
respondents in the petitioners. After the case was received by the new justice of the peace for Lagayan, the
defendants moved for a new trial, invalidating the decision of the justice of the peace of La Paz. The new justice of
the peace of Lagayan declared the judgment null and void, and ordered the case reset for hearing before him.
The Lagayan justice's ground for invalidating the decision of the justice of the peace of La Paz is that "when the
justice having jurisdiction to hear, try and decide the same disqualifies himself, is not in law given to the
disqualifying justice but 'to the judge of the district' who 'shall designate the nearest justice of the peace.' (Section
211, Rev. Adm. Code)."
He believes that the pursuance of which the case was transferred, is legally wrong. The circular states that "when a
justice of the peace is merely disqualified to try a certain case, he should transmit, without notifying the district
judge, the record thereof to the justice of the peace of the nearest municipality in accordance with section 73 of the
Code of the Civil Procedure".
In every case, whether civil or criminal, the disqualification of a justice of the peace, the regular justice shall notify
the auxilliary, who shall thereupon appear and try the cause, unless he shall be likewise disqualified or otherwise
disabled, in which event the cause shall be transferred to the nearest justice of the peace of the province who is not
disqualified.
ISSUE:
1. W/N Respondent Mariano Tuason Jr. (Justice of the Peace of Lagayan) made a proper judgment in declaring the
decision of the justice of the peace of La Paz as null and void.
DOCTRINE:
1. Section 211 of the Revised Administrative Code provides:
Auxilliary justice — ​Qualifications and duties.​ — The auxilliary justice of the peace shall have the same
qualifications and be subject to the same restrictions as the regular justice, and shall perform the duties of
said office during any vacancy therein or in case of the absence of the regular justice.
In case there is no auxilliary justice of the peace to perform the duties of the regular justice in the cases
above-mentioned, the judge of the district shall designate the nearest justice of the peace of the province
whom he may substitute.
2. Section 73 of the Code of the Civil Procedure: "when a justice of the peace is merely disqualified to try a certain
case, he should transmit, without notifying the district judge, the record thereof to the justice of the peace of the
nearest municipality
HELD:
One of the well-established rules of statutory construction enjoins that endeavor should be made to harmonize the
provisions of two laws so that each shall be effective. In order that one law may operate to repeal another law, the
two laws must actually be inconsistent. The former must be so irreconciliable with the latter act. (U.S. ​vs.​ Palacios,
33 Phil., 208.) Merely because a later enactment may relate to the same subject matter as that of an earlier statute is
not of itself sufficient to cause an implied repeal of the latter, since the new law may be cumulative or a continuation
of the old one.
The above-quoted provisions can stand together. By a fair and reasonable construction, section 73 of the Code of
Civil Procedure, as amended, may be said to apply to disqualifications, and section 211 of the Revised
Administrative Code to disqualifications or disabilities not embraced in the Code of Civil Procedure.
From another angle the presumption against repeal is stronger. A special law is not regarded as having been
amended or repealed by a general law unless the intent to repeal or alter is manifest. And if this is true although the
terms of the general act are broad enough to include the matter in the special statute. (Manila Railroad Company ​vs.​
Rafferty, 40 Phil., 224.) At any rate, in the event the harmony between provisions of this type in the same law or in
two laws is impossible, the specific provision controls unless the statute, considered in its entirely, indicates a
contrary intention upon the part of the legislature. granting then that the two laws can not be reconciled, in so far as
they are inconsistent with each other, section 73 of the Code of Civil Procedure, being a specific law, should prevail
over, or considered as an exemption to, section 211 of the Administrative Code, which is a provision of general
character.
But the history of the two laws gives positive indication that they were designed to complement each other. The
purpose to keep both laws in force and subsisting can find no clearer proof than this unless it be an express
declaration of intention.
Wherefore, the appealed decision is reversed with costs against the appellee.
3RD CASE

Topic of the Case: Constitutionality of RA 4790 (that separated 20 barrios from 2 municipalities in the Province of Cotabato, and instead, created
a new municipality named Dianaton under the province of Lanao del Sur)

BARA LIDASAN,​ petitioner,

vs.
COMMISSION ON ELECTIONS,​ respondent.

G.R. No. L-28089 October 25, 1967

SANCHEZ, J.

FACTS:
1. Lidasan, a resident and taxpayer of the detached portion of Parang, Cotabato, and a qualified voter for the 1967
elections assails the constitutionality of RA 4790 and petitioned that Comelec's resolutions implementing the same
for electoral purposes be nullified. Under RA 4790, 12 barrios in two municipalities in the province of Cotabato
are transferred to the province of Lanao del Sur. This brought about a change in the boundaries of the two
provinces.

2. Barrios Togaig and Madalum are within the municipality of ​Buldon in t​ he ​Province of Cotabato,​ and that Bayanga,
Langkong, Sarakan, Kat-bo, Digakapan, Magabo, Tabangao, Tiongko, Colodan and Kabamakawan are parts and
parcel of another municipality, the municipality of ​Parang,​ also in the Province of Cotabato ​and not of Lanao del
Sur.

3. Apprised of this development, the Office of the President, recommended to Comelec that the operation of the statute
be suspended until "clarified by correcting legislation."

4. Comelec, by resolution declared that the statute should be implemented unless declared unconstitutional by the
Supreme Court.

ISSUE: Whether or not RA 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 is unconstitutional for embracing
more than one subject in the title

HELD: YES. RA 4790 is null and void

1. 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. Of relevance here is the second directive. The subject of the statute must be "expressed in the title" of the
bill. This constitutional requirement "breathes the spirit of command." Compliance is imperative, given the fact
that the Constitution does not exact of Congress the obligation to read during its deliberations the entire text of the
bill. In fact, in the case of House Bill 1247, which became RA 4790, only its title was read from its introduction to
its final approval in the House where the bill, being of local application, originated.

2. The Constitution does not require Congress to employ in the title of an enactment, language of such precision as to
mirror, fully index or catalogue all the contents and the minute details therein. It suffices if the title should serve
the purpose of the constitutional demand that it inform the legislators, the persons interested in the subject of the
bill, and the public, of the nature, scope and consequences of the proposed law and its operation. And this, to lead
them to inquire into the body of the bill, study and discuss the same, take appropriate action thereon, and, thus,
prevent surprise or fraud upon the legislators.

3. 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.

4. The title — "An Act Creating the Municipality of Dianaton, ​in the Province of Lanao del Sur"​ — projects the
impression that only 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.

5. Finally, the title did not inform the members of Congress the full impact of the law. One, 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.
Two, it kept the public in the dark as to what towns and provinces were actually affected by the bill.

----------------------------------------------------------------------------------------------------------------------------------------------------

4TH CASE
Ichong, etc., et al. v. Hernandez, etc., and Sarmiento
Case No. 133
G. R. No. L-7995 (May 31, 1957)

FACTS:
Petitioner is a Chinese merchant who questions the constitutionality of RA 1180 “An Act to Regulate the Retail
Business” on the following grounds:
a) It is a violation of the Equal Protection of the Law Clause, denies them of their liberty, property and due process
of law
b) It is a violation of the constitutional requirement that a bill’s title must reflect the subject matter of the same
because “regulate” does not really mean “nationalize” and “prohibit”
c) The Act violates International treaties and Laws

ISSUE:​ W/N RA 1180 is constitutional.

HELD: RA 1180 is constitutional. In the above-mentioned case, what has been pointed out is the constitutional
requirement that “A bill shall embrace only one subject as expressed in its title.” This is to prohibit duplicity in
legislation because the title must be able to apprise legislators and the public about the nature, scope, and
consequences of that particular law. Constitution precludes the encroaching of one department to the responsibilities
of the other departments. The legislature is primarily the judge of necessity, adequacy, wisdom, reasonableness, and
expediency of the law, and the courts have no jurisdiction to question this.

STATUTORY CONCEPT/ LATIN MAXIMS:

9a: ​Ratio legis est anima legis. ​The reason of the law is the soul of the law.

24a: Chapter V – INTERPRETATION OF WORDS AND PHRASES

​ eneral words should be understood in their general
Generalia verba sunt generaliter intelligenda. G
sense.

d:TITLE OF THE ACT (INTRINSIC AID) Nigrum Nunquam Excedere Debet Rubrum.
The black (body of the act printed in black) should never go beyond the red (title or rubric of the statute printed in
red).
5TH CASE
Mun.of Panganiban v Shell Co.of the Phil.,Ltd.,

Summary: Shell Company alleging the constitutionality of Act to provide Means for Increasing the Highway Special
Fund because the title renders 2 subject matter

FACTS:
This is an appeal from the decision of the Court of First Instance of Manila dismissing the Plaintiff’s complaint for
the collection of sales taxes from Defendant on the ground that the law which authorizes collection of the same is
unconstitutional. Defendant Company refused to pay taxes accruing from its sales because according to them the
taxable sites of the property sought to be taxed is not the said Municipality. According to the Defendant, RA 1435 or
Act to Provide Means for Increasing Highway Special Fund is unconstitutional because it embraces two subjects
which are:
1) amendment of the tax code, and
2) grant of taxing power to the local government, and makes reference to Road and Bridge Fund.

ISSUE:
W/N RA 1435 is constitutional.

HELD:
RA 1435 is constitutional because it embraces only one subject reflected by its title “Road and Bridge Fund.”
Statutory definition prevails over ordinary usage of the term. The constitutional requirement as to the title of the bill
must be liberally construed. It should not be technically or narrowly construed as to impede the power of legislation.
When there is doubt as to its validity, it must be resolved against the doubt and in favor of its validity. In the
abovementioned cases, what is pointed out is the constitutional requirement that “A bill shall embrace only one
subject, expressed in its title.” This is to prohibit duplicity in legislation because the title must be able to apprise
legislators and the public about the nature, scope, and consequences of that particular law.

STATCON Concept/LATIN MAXIM:

The bill shall embrace only one subject. To prohibit duplicity in legislation. The subject should clearly
state the nature, scope, and consequences of the laws or its operation (page 11- Agapalo)
12a: Ea est accipienda interpretation quae vitio caret. That interpretation is to be adopted which is free
from evil or injustice. 37: Interpretatio fienda est ut res magis valeat quam pereat.
A law should be interpreted with a view of upholding rather than destroying it.

TITLE OF THE ACT (INTRINSIC AID)

D. Nigrum Nunquam Excedere Debet Rubrum.
The black (body of the act printed in black) should never go beyond the red (title or rubric of the statute printed in
red).
6TH CASE
Topic of the Case: NPC Contract Renewal
Petitioner/Plaintiff: Santiago Alalayan
Responded/Defendant: National Power Corporation
Other parties involved

G.R. No. L-24396

Santiago Alalayan Vs. National Power Corporation
Fernando J.

ISSUE: W/N Section 3 is a subject which the bill title “An Act to Further Amend Commonwealth Act No. 121”
does not embrace, thus making it a rider because it is violative of the constitutional provision requiring that “a bill,
which may be enacted into law, cannot embrace more than one subject, which shall be expressed in its title.”
Amendment is of other policy than the main policy

Two Proviosns
1. "in any contract for the supply of electric power to a franchise holder," receiving at least 50% of its electric
power and energy from it to require as a condition that such franchise holder "shall not realize a net profit of more
than twelve percent annually of its investments plus two-month operating expenses." (Franchise giving and criteria)
2. Rider provision: "renew all existing contracts with franchise holders for the supply of electric power and
energy," (Renewal of franchise)

HELD: Section 3 is constitutional. Republic Act 3043 is an amendatory act. It is sufficient that the title makes
reference to the legislation to be amended (in this case Commonwealth Act 121). Constitutional provision is
satisfied if title is comprehensive enough to include the general object which the statute seeks to effect without
expressing each and every ends and means necessary for its accomplishment. Title doesn’t need to be a complete
index of the contents of the act.

LATIN MAXIM:
24a: Chapter V – INTERPRETATION OF WORDS AND PHRASES Generalia verba sunt generaliter
intelligenda. General words should be understood in their general sense.
37: Interpretatio fienda est ut res magis valeat quam pereat. A law should be interpreted with a view of upholding
rather than destroying it.
TITLE OF THE ACT (INTRINSIC AID)
D. Nigrum Nunquam Excedere Debet Rubrum. The black (body of the act printed in black) should never go
beyond the red (title or rubric of the statute printed in red).
7th case (e)
Topic of the Case: Creation of City of Sorsogon
Petitioner/Plaintiff: Benjamin Cawaling
Responded/Defendant: Commission on Election

G.R. No. 146319

Benjamin Cawaling vs. Commission on Elections
Sandoval Gutierrez

Facts:
· That President Estrada signed into law RA 8806 “"Act Creating The City Of Sorsogon By Merging The
Municipalities Of Bacon And Sorsogon In The Province Of Sorsogon, And Appropriating Funds Therefor."” (Aug
16, 2000)
· That Commission on Elections conducted a plebescite in the Municipalities of Bacon and Sorsogon, pursuant
to Sec 10, Article X of the 1987 consti (Dec 10, 2000)
· That Plebiscite City Board of Canvassers (PCBC) proclaimed the ratification that creates the City of Sorsogon
(Dec 17, 2000)
· That Cawaling contested and filed for petition of certiorari seeking the annulment of the pleb w/ the grounds
of:
o Ratification already lapsed the 120 days prescription from the approval
o Comelec failed to observe 20 days of intensive information drive in both municipalities
· That Cawaling also filed for petition for prohibition and enjoin the futher implementation of RA 8806 as it
being unconstitutional on the grounds of
o Cited sec 10, art x of the 1987 consti, that "a municipality or a cluster of barangays may be converted into a
component city" which the proposed cited have merged 2 municipalities
o Violated the one subject- one bill as prescribe by Sec 26 (1) Art. VI of the 1987 Consti

Issues:
1. WON the creation of the city is constitutional
2. WON the law violates the one subject-one bill
3. WON the COMELEC violated the 120 day prescription
4. WON COMELEC failed in conducting information drive prior to the pleb
Held:
1. YES
2. NO
3. NO
4. NO
Ratio:
1. The petitioner challenged the mode of creation not the criteria prescribe by the code.
a. “He contends that under Section 450(a) of the Code, a component city may be created only by converting
"a municipality or a cluster of barangays," not by merging two municipalities, as what R.A. No. 8806 has done.”
b. The above provision is not a criterion but a modes which a city may be created.
c. The petitioner also argued that there is no compelling reason for the merge, but the ponente cited Justice JP.
Laurel. "may not annul an act of the political departments simply because we feel it is unwise or impractical. "
2. That the law is does have in subscription with the one subject-one bill policy, thus the law’s main purpose
is the creation of the City of Sorsogon. Thus, the abolition of the municipality of bacon is a result to the creation of a
new unit. ​(one subject-one rule)
3. The COMELEC contended, which the court sided with argument, that the law is a subject to the publication
requirement for a law to be deem in-effect. Thus, the prescription of 120 should be counted after the publication on 2
newspaper of publication and not with the approval of president Estrada
4. The plaintiff failed to provide evidence a proof to solidify his claim. With absence of concrete proof, the
court sustain the presumption that COMELEC performed its duty.
8th case
Topic of the Case: Fake Doctor
Petitioner/Plaintiff: The People of the Philippine Islands
Responded/Defendant: Jovita Buenviaje
Other parties involved

G.R. No. L-22945

The People of the Philippine Islands vs. Jovita Buenviaje
OSTRAND, J.

Facts:

• The Buenviaje claims to be a doctor, but without board medical examiners ‘certificate of registration
• w/o a license, Buenviaje, voluntarily, illegally and criminally and for compensation, practiced medicine in
the City of Manila, Philippine Islands.
• That the defendant assisted, treated and manipulated the head and body of Regino Noble for the purpose of
curing him of the ailments, diseases, pains and physical defects from which he pretended to suffer, and advertising
and offering her services as a physician
• Presented herself as Doctor in various prints like cards she distributed and letterheads an signs outside her
office situated, and in newspapers which are published and circulated in the City of Manila. Moreover, uses the title
of “Dra” to all prints mentioned, which is the abbreviation of the word `doctor,' for the purpose of causing the public
to believe that she, the said defendant, had received the corresponding title of doctor
• That she admitted to all the aforementioned information, but she contested that she on or about the first day
of June, 1923, and for some time prior to that date, advertised herself as a `doctor of chiropractic,'
• that she was graduated a doctor in chiropractic on the 13th day of August, 1919, as evidenced by a
certificate marked Exhibit I and issued by the American University School of Chiropractic of Chicago, Illinois

Issues: WON the Act No. 3111, amending section 770 of the Administrative Code is constitution
Held: YES
Ratio:
1. Under constitutional provisions similar to ours the general rule is that a title which declares the amendatory
statute to be an act to amend a designated section or the like of a specified Code is sufficient and the precise nature
of the amendatory Act need not be further stated. ​(one-subject-one bill rule)
9TH CASE

Topic of the Case: Agrarian Counsel Dispute

Petitioner/Plaintiff: Manuel Cordero
Responded/Defendant: Jose Cabatuando

G.R. No. L-14542

Manuel Cordero vs. Jose Cabatuando
Regala J.

Facts:

• That Tenancy Counsel Unit of the Agricultural Tenancy Commission of the Department of Justice thru its
Trial Attorney the herein petitioner Manuel A. Cordero as counsel for indigent petitioner tenant Vicente Salazar.
o Filed against respondent landlord Leonardo Sta. Romana and others "for reinstatement and reliquidation of
past harvests"; t
• That on September 22, 1958, respondent Judge, acting on the aforesaid motion to qualify, issued an order
disqualifying Manuel Cordero and/or other attorney from from the Mediation Division of the Department of Justice
from appearing as counsel for petitioner tenant Vicente Salazar or for other tenants represented by the said division
the said court;
• The Court Agrarian Relations (Second Regional District) upheld that
o The representation of tenants who cannot afford to pay should be done by the public defendant of the DOJ
as provided by Sec 54 of the RA 1199
o That the Tenancy Unit Counsel in the Mediation Division creation is no legal force
o That Mediation Division of the Agricultural Tenancy Commission is operating w/o any statute
• That congress enacted Republic Act No. 2263, amending Republic Act No. 1199
o This bill amending the 53 and 54 of Republic Act No. 1199 – “In all cases wherein a tenant cannot afford to
be represented by counsel, it shall be the duty of the trial attorney of the tenancy mediation commission to represent
him”
• That the bill violated the one subject-one bill rule.
o He contended further that nowhere in the titles of Republic Act No. 1199 and Republic Act No. 2263 is the
creation of the Tenancy Mediation Division ever mentioned,

Issues: WON the bill violated the one subj-one bill rule
Held: No.

Ratio:
• The only amendment brought about by Republic Act No. 2263 is the transfer of the function of representing
these indigent tenants to the Department of Justice, apparently to consolidate in the latter Department the functions
relative to the enforcement of tenancy laws.
• In essence, therefore, there is no change in the set-up established by Republic Act No. 1199 and that
provided for by Republic Act No. 2263
Decision: The provisions were constitutional
10th case

Topic of the Case: Conversion of Mandaluyong

Petitioner/Plaintiff: Robert Tobias
Responded/Defendant: Benjamin Abalos

G.R. No. L-114783

Rober Tobias Et. al vs. Benjamin Abalos
Bidin J.

Facts:
· The municipalities of Mandaluyong and San Juan belonged to only one legislative district.
o 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." Was passed in congress and signed into law by President
Ramos
· The plebiscite was conducted on April 10, 1994; By virtue of these results, R.A. No. 7675 was deemed
ratified and in effect.
· Petitioners alleges subject law resulted in the latter embracing two principal subjects. "one subject-one bill"
rule has not been complied with
o the conversion of Mandaluyong into a highly urbanized city
o the division of the congressional district of San Juan/Mandaluyong into two separate districts.
· Petitioners argues that the separation of the congressional districts is beyond provided in Article VI, Sec. 5(1)
of the Constitution.
· petitioners argued that the laws preempts the right of Congress to reapportion legislative districts pursuant to
Sec. 5(4)

Issue: W/N the aforestated subject is germane to the subject matter of R.A. No. 7675.
HELD: RA 7675 is constitutional. 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 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. The Constitution does not require Congress to employ in the title of an enactment, language
of such precision as to mirror, fully index or catalogue all the contents and the minute
details therein.
LATIN MAXIM:
20a, Implications: Ex necessitate legis. By the necessary implication of law.

TITLE OF THE ACT (INTRINSIC AID)

D. Nigrum Nunquam Excedere Debet Rubrum. The black (body of the act printed in black) should never go
beyond the red (title or rubric of the statute printed in red).
(Case Number 11)
Topic of the Case: Validity of a Provision
Petitioner/Plaintiff: Ayson and Ignacio
Responded/Defendant: The Provincial Board of Rizal and The Municipal Council of Navotas

GR NUMBER: G.R. No. 14019

TITLE: Ayson v.s. Provincial Board of Rizal
PONENTE: Malcolm, J.

Facts:
- On September 17, 1916, the municipal council of Navotas Rizal adopted is ordinance No. 13, Section 2.
- This ordinance provided that “all owners and proprietors of the industry known as fishing, with nets
denominated as ‘cuakit’ and ‘pantukos’, before engaging in fishing in the bay of this jurisdiction within three
leagues from the shore-line of this municipality, are obliged to provide themselves with a license issued by this
municipal government, after payment of a fee of P50 annually, payable every three months.”
- The petitioners then filed this case on the grounds of the invalidity of Section 2270 of the Administrative Code
of 1916, now Section 2324 of the Administrative Code of 1917.
Issues:
- Whether or not Section 2270 of the Administrative Code of 1916, now Section 2324 of the Administrative
Code of 1917, is valid.
- Whether or not the Philippine Legislature has the power to change any portion of the Philippine law.
- Whether or not the Administrative Code embraces more than one subject.
Ruling:
- Denied the petition for a preliminary injunction and absolving the defendants from the complaint without
special findings as to costs, is affirmed, with costs of this instance against the appellants.
Ratio:
- No organic law prohibits the Philippine Legislature from amending or repealing any portion of Philippine law.
- The Administrative Code of 1916 is nether private or local bill, both of which should just have one subject.
- The Administrative Code of 1917 is entitled “An Act amending the Administrative Code”. The Administrative
Code of 1917 basically just amends Administrative Code of 19; therefore, there was no violation of the Jones
Law (i.e. that no bill which may be enacted into law shall embrace more than one subject and that subject be
expressed in the title of the bill).
-> Single-subject rule
Topic of the Case: One subject-One Rule (Case Number 12)
Petitioner/Plaintiff: The People of the Philippines
Responded/Defendant: Valeriano Valensoy Y Masa

GR NUMBER: G.R. No. L-9659

TITLE: People v. Valensoy
PONENTE: Padilla, J.

Facts:
- In criminal case No. 1780, Valensoy was charged in the Court of First Instance of Manila with a violation of
Section 26, No. 1780 because of the concealment of a bolo.
- He motioned to quash the information on the grounds of Act No. 1780 reiterating that the Act regulated the
importation, acquisition, possession, use, and transfer of firearms, which didn’t include other weapons such as a
bolo.
- The trial court denied the motion on the ground that at the time of enactment of Act. No.1780 the prohibition
had reference to private or local bills.
- At the trial the respondent admitted the facts alleged in the information but was not guilty simply because the
Act No.1780 could not and did not include weapons like bolos.
- The trial court found the defendant as reasonable as charged.
- The defendant then appealed in this case.
Issues:
- Whether or not the Act No.1780 is a private or local bill.
- Whether or not the provisions of Act No.1780 is binding (i.e. in line with the Constitution).
Ruling:
- The appeal is affirmed
- Costs against the appellant
Ratio:
- Act No. 1780 had reference to private or local bills on October 12, 1907. However, Act No. 1780 has been
repealed by the 1935 Constitution. These laws then become binding on everyone, unlike a private or local bill.
Thus in can embrace more than one subject which, in this case, includes weapons that aren’t just firearms but
also weapons like the bolo.
Topic of the Case: Constitutionality of the People’s Court (Case number 13)
Petitioner/Plaintiff: The People of the Philippines
Responded/Defendant: Apolonio Carlos

GR NUMBER: G.R. No. L-239

TITLE: People v. Carlos
PONENTE: Tuason, J.:

Facts:
- On July/August 1944, about two or three o’clock in the morning, that a truck pulled up to the curb in front of a
house on Constancia Street, Sampaloc, Manila, where one Martin Mateo lived.
- The accused, a Japanese spy, pointed the house of Martin Mateo and Fermin Javier to the Japanese military.
- The Japanese military broke into the houses of Mateo and Javier. The following people were abducted: Martin
Mateo, Ladislao, and Fermin Javier.
- They were tortured in Fort Santiago, for the reason of not divulging the whereabouts of Marcelino Mateo.
- The People’s Court found Apolonio Carlos of treason.
- The respondent assailed the constitutionality of the People’s Court.
Issues:
- Whether or not the People’s Court is unconstitutional or not.
Ruling:
- The judgment of the lower court is affirmed with costs against appellant.
Ratio:
- The People’s Court is a court of special and restricted jurisdiction created under the stress of an emergency and
national security. Moreover, with its associate feature the People’s Court is designed to extend greater
protection to persons charged with collaboration with the enemy. If others are prosecuted before a Court of First
Instance, they and not the respondent should have cause to complain.
- Section 22 in denying preliminary investigation to persons accused before the People’s Court is justified by
the conditions prevailing when the law was enacted.
- The People’s Court is a collegiate Court whereas the Court of First Instance is presided over by a single judge.
Therefore, the appeal is not constitutional but a statutory right.
- A court is an entity possessing a personality separate and distinct from the men who compose it. Also, the
Constitution does not insure uniformity of judicial decisions.

Topic of the Case: Exemption from margin fee on finished products (Case 14)
Petitioner/Plaintiff: Casco Philippine Chemical., Inc.
Responded/Defendant: Hon. Pedro Gimenez and Hon. Ismael Mathay

GR NUMBER: G.R. No. L-17931

TITLE: Casco Philippine Chemical Co. Inc. v. Hon. Pedro Gimenez
PONENTE: Concepcion, J:

Facts:
- Pursuant to the provisions of Republic Act No. 2609, otherwise known as the Foreign
Exchange Margin Fee Law, the Central Bank of the Philippines issued on July 1, 1959, its
Circular No. 95. fixing a uniform margin fee of 25% on foreign exchange transactions.
- To supplement the circular, the Bank later promulgated a memorandum establishing the
procedure for applications for exemption from the payment of said fee, as provided in said
Republic Act No. 2609.

- Several times in November and December 1959, petitioner Casco Philippine Chemical Co.,
Inc. — which is engaged in the manufacture of synthetic resin glues, used in bonding lumber
and veneer by plywood and hardwood producers — bought foreign exchange for the
importation of urea and formaldehyde — which are the main raw materials in the production
of said glues — and paid therefor the aforementioned margin fee aggregating P33,765.42.

- In May, 1960, petitioner made another purchase of foreign exchange and paid the sum of
P6,345.72 as margin fee therefor.

- Prior thereto, petitioner had sought the refund of the first sum of P33,765.42, relying upon
Resolution No. 1529 of the Monetary Board of said Bank, dated November 3, 1959,
declaring that the separate importation of urea and formaldehyde is exempt from said fee.

- Soon after the last importation of these products, petitioner made a similar request for
refund of the sum of P6,345.72 paid as margin fee therefor.

- Although the Central Bank issued the corresponding margin fee vouchers for the refund of
said amounts, the Auditor of the Bank refused to pass in audit and approve said vouchers,
upon the ground that the exemption granted by the Monetary Board for petitioner's separate
importations of urea and formaldehyde is not in accord with the provisions of section 2,
paragraph XVIII of Republic Act No. 2609.

- On appeal taken by petitioner, the Auditor General subsequently affirmed said action of the
Auditor of the Bank. Hence, this petition for review.
Issues:
- Whether or not “urea” and “formaldehyde” are exempt by law from the payment of the
margin fee
Ruling:
- The decision appealed from is hereby affirmed, with costs against the petitioner
Ratio:
- “Urea Formaldehyde” is a finished product used in Section 2 of Republic Act 2609, which
is distinct from “Urea” and “Formaldehyde”. Thus the importation of both, separately, is not
exempted from the imposed margin fee.