Title

Cordero v.
Cabatuando

Bill
RA 2263:
Agricultural Tenancy
Act of the the
Philippines

Philconsa v.
Gimenez

RA 3863: An Act
Amending
Subsection (C), Sec
12 of
Commonwealth Act
No. 186 as amended
by RA 3096
(retirement gratuity
& commutation of
vacation and sick
leave for GSIS
members)

Alalayan v. NPC

RA 3043 An Act to
Further amend CA
120, as amended by
RA 2641

Problem Subject
Sec 19 & 20 (authorizes SOJ
through a tenancy mediation
division to carry out a national
enforcement program
including the mediation of
tenancy disputes is not
expressed in the title)
Provision for the retirement of
members and certain officers
of Congress is not expressed
in the title. It is a way of
circumventing the
Constitution, by the act of
increasing emoluments.
Pet claim: no inkling or notice
whatsoever to the public
regarding the retirement
gratuities and commutable
vacation and sick leave
privileges to members of the
Congress
Sec 3: shall not realize a not
profit of more than 12%
annually of its investments
plus two-month operating
expenses -> renew all
existing contracts with
franchise holders for the
supply of electric power and
energy
in reality: empowers the NPC
to require as a condition that

Valid/Invalid
VALID

Why
It only provided for a transfer of the function
representing these indigent tenants to the
Department of Justice to consolidate
functions in the DOJ, relative to enforcement
of tenancy laws.

INVALID

Members of the Congress and other elective

officers were not part of the GSIS.

VALID

It is enough that the title is comprehensive

enough reasonably to include the general
object which the statute seeks to effect
without expressing each and every means
necessary for its accomplishment, mere
details need not be set forth.
Persons and property may be subjected to
all kinds of restraints and burdens, in order
to secure the general comfort, health, and
prosperity of the state.

Insular Lumber
Company v. CTA

RA 1435: An Act to
Provide Means for
Increasing the
Highway Special
Fund

a franchise holder receiving at

least 50% of its electric power
and energy from it to realize a
net profit of not more than
12% annually of its
investments plus two-month
operating expenses. It further
empowers the NPC to renew
all existing contracts with
franchise holders for the
supply of electric power and
energy.
Sec 5: partial exemption of
miners and loggers (refund of
25% of tax when upon
submission of proof of actual
use of oils and under similar
conditions)

VALID

Not a deviation from the original subject

since imposition of tax is a way for
increasing such fund while exemptions are
always involved in imposition of taxes.
It is also limited to 5 years.

Partial exemption: deals with

another subject

Tio v. Videogram
Regulatory Board

Phil. Judges
Assn. v. Prado

PD 1987: An Act
Creating the VRB

RA 7354 as
implemented by
Circular No.92-28
An Act Creating the

Sawmiil <-> forest

concessions
Sec 10: impose a tax on 30%
on the gross receipts

Sec 35 withdrawal franking

privileges of the judiciary

VALID

VALID

It is germane to the general purpose that the

statute seeks to achieve. Titles should not
be narrowly construed to cripple/impede
power of legislation.
-> taxation of video industry = regulation
Title of the bill is not required to be an index
to the body of the act. It fairly indicates the
general subject It aims to serve the principal
objective which is the creation of more
efficient and effective postal service system.

Tolentino v.
Secretary of
Finance

Tobias v. Abalos

Philippines Postal
Corporation,
Defining its Powers,
Functions and
Responsibilities,
Providing for
Regulation of the
Industry and for
Other Purposes
Connected
Therewith
RA 7716: An Act
Restructuring the
VAT System,
Widening its Tax
Base and Enhacing
its Administration,
and for these
Purposes Amending
and Repealing the
Relevant Provisions
of the NIRC
RA 7675: An Act
Converting the
Municipality of
Mandaluyong into a
Highly Urbanized
City to be known as
City of Mandaluyong

Removal of PAL exemption

VALID

Congress can grant a franchise for the

operation of a public utility and at the same
time amend, alter or repeal such when the
common good so requires.

Art VII, Sec 49

VALID

It was a natural and logical consequence.

Applying a liberal construction, it should be
given a practical and not technical
construction. It should be sufficient that the
title expresses the general subject and all
provisions are germane to the title.

City of Mandaluyong shall

have its own legislative district
with the first representative to
be elected in the next national
elections after the passage of
the act while the remainder of
the former legislative district
of San Juan/Mandaluyong
shall become the new
legislative district of San Juan
with its first representative to

be elected at the same

election

Tatad v. Sec. of
DOE

De Guzman v.
COMELEC

Cawaling v.
COMELEC

BANAT v.
COMELEC

RA 8180: An Act
Deregulating the
Downstream Oil
Industry and For
Other Purposes
RA 8189: The
Voters Registration
Act of 1996

RA 8806: An Act
Creating the City of
Sorsogon By
Merging the
Municipaities of
Bacon and
Sorsogon in the
Province of
Sorsogon, And
Appropriating Funds
Thereof
RA 9369: AN ACT
AMENDING RA
8436 USE OF
AUTOMATED
ELECTON SYSTEM
IN THE MAY 199,

Coversion + division into two

separate districts
- second subject is not
germane to the title
Sec 5(b) providing for tariff
deferential
3% on CO and 7% on
imported refined PP
Sec 44: Reassignment of
Election of Officers no one
should hold office in a
particular city of municipality
for more than 4 years ->
automatically reassigned
Contains 2 subjects: a)
creation of the City of
Sorsogon and b) abolition of
the Municipalities of Bacon
and Sorsogon

Sec 34: Watchers

Sec. 37: Congress +
COMELEC En Banc as NBC
Sec.38: Pre-Proclamation
Cases
Sec 43: amending BP 881

VALID

VALID

Germane to the subject. Title need to be a

full index. The section is supposed to sway
prospective investors to put up refineries in
our country and make them rely less on
imported petroleum.
Germane to subject general subject and title.
It is related to the conduct and procedure of
registration of voters.

VALID

Abolition was a logical, natural and inevitable

consequence. Title need not to contain full
index or catalogue. A liberal stance should
be taken in the construction of the title.

VALID

Title is broad enough. It is amendatory of RA

8436, BP 881, RA 7166 and other election
laws to achieve its purpose of promoting
transparency, credibility, fairness and
accuracy in the elections.

1998
ELECTIONS..

Prosecution and investigation

of election offenses