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Title Bill Problem Subject Valid/Invalid Why

Cordero v.Cabatuando

RA 2263:Agricultural TenancyAct of the the

Philippines

Sec 19 & 20 (authorizes SOJthrough a tenancy mediationdivision to carry out a national

enforcement programincluding the mediation oftenancy disputes is notexpressed in the title)

VALID It only provided for a transfer of the functionrepresenting these indigent tenants to theDepartment of Justice to consolidate

functions in the DOJ, relative to enforcementof tenancy laws.

Philconsa v.Gimenez

RA 3863: An ActAmendingSubsection (C), Sec12 ofCommonwealth Act

No. 186 as amendedby RA 3096

(retirement gratuity& commutation ofvacation and sickleave for GSISmembers)

Provision for the retirement ofmembers and certain officersof Congress is not expressedin the title. It is a way ofcircumventing the

Constitution, by the act ofincreasing emoluments.

Pet claim: no inkling or noticewhatsoever to the publicregarding the retirementgratuities and commutablevacation and sick leaveprivileges to members of theCongress

INVALID Members of the Congress and other electiveofficers were not part of the GSIS.

Alalayan v. NPC RA 3043 An Act toFurther amend CA

120, as amended byRA 2641

Sec 3: shall not realize a notprofit of more than 12%

annually of its investmentsplus two-month operatingexpenses -> renew allexisting contracts withfranchise holders for thesupply of electric power andenergy

in reality: empowers the NPCto require as a condition that

VALID It is enough that the title is comprehensiveenough reasonably to include the general

object which the statute seeks to effectwithout expressing each and every meansnecessary for its accomplishment, meredetails need not be set forth.

Persons and property may be subjected toall kinds of restraints and burdens, in orderto secure the general comfort, health, andprosperity of the state.

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a franchise holder receiving atleast 50% of its electric powerand energy from it to realize anet profit of not more than12% annually of itsinvestments plus two-monthoperating expenses. It furtherempowers the NPC to renewall existing contracts withfranchise holders for thesupply of electric power andenergy.

Insular LumberCompany v. CTA

RA 1435: An Act toProvide Means forIncreasing the

Highway SpecialFund

Sec 5: partial exemption ofminers and loggers (refund of25% of tax when upon

submission of proof of actualuse of oils and under similarconditions)

Partial exemption: deals withanother subject

Sawmiil forestconcessions

VALID Not a deviation from the original subjectsince imposition of tax is a way forincreasing such fund while exemptions are

always involved in imposition of taxes.

It is also limited to 5 years.

Tio v. Videogram

Regulatory Board

PD 1987: An Act

Creating the VRB

Sec 10: impose a tax on 30%

on the gross receipts

VALID It is germane to the general purpose that the

statute seeks to achieve. Titles should notbe narrowly construed to cripple/impedepower of legislation.

-> taxation of video industry = regulation

Phil. JudgesAssn. v. Prado

RA 7354 asimplemented byCircular No.92-28

An Act Creating the

Sec 35 withdrawal frankingprivileges of the judiciary

VALID Title of the bill is not required to be an indexto the body of the act. It fairly indicates thegeneral subject It aims to serve the principalobjective which is the creation of moreefficient and effective postal service system.

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Philippines PostalCorporation,Defining its Powers,Functions andResponsibilities,Providing forRegulation of theIndustry and forOther PurposesConnectedTherewith

Tolentino v.Secretary ofFinance

RA 7716: An ActRestructuring theVAT System,Widening its Tax

Base and Enhacingits Administration,and for thesePurposes Amendingand Repealing theRelevant Provisionsof the NIRC

Removal of PAL exemption VALID Congress can grant a franchise for theoperation of a public utility and at the sametime amend, alter or repeal such when thecommon good so requires.

Tobias v. Abalos RA 7675: An Act

Converting theMunicipality ofMandaluyong into aHighly UrbanizedCity to be known asCity of Mandaluyong

Art VII, Sec 49

City of Mandaluyong shallhave its own legislative districtwith the first representative tobe elected in the next nationalelections after the passage ofthe act while the remainder ofthe former legislative districtof San Juan/Mandaluyongshall become the new

legislative district of San Juanwith its first representative to

VALID It was a natural and logical consequence.

Applying a l iberal construction, it should begiven a practical and not technicalconstruction. It should be sufficient that thetitle expresses the general subject and allprovisions are germane to the title.

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be elected at the sameelection

Coversion + division into twoseparate districts- second subject is notgermane to the title

Tatad v. Sec. ofDOE

RA 8180: An ActDeregulating theDownstream OilIndustry and ForOther Purposes

Sec 5(b) providing for tariffdeferential

3% on CO and 7% onimported refined PP

VALID Germane to the subject. Title need to be afull index. The section is supposed to swayprospective investors to put up refineries inour country and make them rely less onimported petroleum.

De Guzman v.

COMELEC

RA 8189: The

Voters RegistrationAct of 1996

Sec 44: Reassignment of

Election of Officers no oneshould hold office in a

particular city of municipalityfor more than 4 years ->automatically reassigned

VALID Germane to subject general subject and title.

It is related to the conduct and procedure ofregistration of voters.

Cawaling v.COMELEC

RA 8806: An ActCreating the City ofSorsogon ByMerging theMunicipaities ofBacon andSorsogon in the

Province ofSorsogon, AndAppropriating FundsThereof

Contains 2 subjects: a)creation of the City ofSorsogon and b) abolition ofthe Municipalities of Baconand Sorsogon

VALID Abolition was a logical, natural and inevitableconsequence. Title need not to contain fullindex or catalogue. A liberal stance shouldbe taken in the construction of the title.

BANAT v.COMELEC

RA 9369: AN ACTAMENDING RA

8436 USE OFAUTOMATEDELECTON SYSTEMIN THE MAY 199,

Sec 34: WatchersSec. 37: Congress +

COMELEC En Banc as NBCSec.38: Pre-ProclamationCasesSec 43: amending BP 881

VALID Title is broad enough. It is amendatory of RA8436, BP 881, RA 7166 and other election

laws to achieve its purpose of promotingtransparency, credibility, fairness andaccuracy in the elections.

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1998ELECTIONS!..

Prosecution and investigationof election offenses