Remman Enterprises, INC.
and Chamber of Real Estate and Builders’ Association, and means necessary or convenient for accomplishing of that object. The title need not
vs. Professional Regulatory and Board of Real Estate Service and Professional
Regulation Commission
FACTS:
R.A. No. 9646, Real Estate Service Act of the Philippines was signed into a law
on June 29 2009. Its IRR was promulgated on June 21, 2010 by the PRC and PRBRES. On
December 07, 2010, herein petitioners filed a civil case on the RTC of Manila, Branch 42
seeking to declare the said law void and unconstitutional. Petitioners claim that the
s=new law violates Article VI, Section 26(1) of the 1987 Philippines Constitution which
mandates that “every bill passed by Congress shall embrace only one subject which
shall be expresses in the title thereof”. The RTC held that the assailed provisions are
relevant to the title of the law as they are intended to regulate the practice of real
estate service in the country by ensuring that those who engage in it shall either be a
licensed real estate broker, or under the latter’s supervision, the petition is therefore
DENIED by the this court.
ISSUE:
Whether or not R.A. No. 9646 is unconstitutional for being violative of the
“one-title-one-subject” rule under Article VI, Section 26(1) of the Philippine Constitution.
HELD:
To determine whether there has been compliance with the constitutional
requirement, the Court laid down the rule that— constitutional provisions relating to the
subject matter and titles of statues should not be so narrowly construed as to cripple
or impede the power of legislation.
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
be am abstract or index of the Act.
The Court has previously rules that the one-subject requirement under the
constitution is satisfied if all the parts of the statute are related and are germane to the
subject matter expressed in the title, or as long as they are not inconsistent with or
foreign to the general subject and title.
Norma A. Del Socorro vs. Ernst Johan Brickman Van Wilsem
FACTS:
Petitioner Del Socorro and respondent Van Wilsem contracted marriage in
Holland on September 25, 1990, they have a son, Roderigo Norjo Van Wilsem, who was 16
years old at the time of filing of the instant petition.
By virtue of a divorce decree issued by the appropriate Court of Holland, they
separated. Thereafter, petitioner and her son came back to the Philippines.
Respondent failed to comply with his promise to provide monthly support in
the amount of P17,500 per month (250 guidene). Respondent came back to the
Philippines and remarried in Pinamungahan, Cebu and have been residing thereat.
Petitioner send a letter to the respondent, demanding for support, respondent refused.
Petitioner then filed a complaint-affidavit with the Provincial Prosecutor
against the respondent for violation of Section 5, paragraph E(2) of R.A. No. 9262
ISSUE:
Whether or not a foreign national has an obligation to support his minor child
under Philippine law despite the fact that the law of the country is of the said foreign
national do not oblige the parents to support their children.
HELD:
 In the international law, the party who want to have a foreign law applied to a
dispute or case has the burden of proving the foreign law. While respondent pleaded the
laws of the Netherland in advancing his position that he is not obliged to support his son,
he never proved the same.

The doctrine of processual presumption shall govern. Under this doctrine, if

the foreign law involved is not properly pleaded and proved in the instant case, it is
presumed to be the same with Philippine law, which enforces the obligation of parents
to support their children and penalizing the non-compliance therewith.

Moreover, foreign law should not be applied when its application would work
undeniable injustice to the citizens or residents of the forum.