Philippine Judges Association Vs.

Prado Case Digest
Philippine Judges Association Vs. Prado 227 SCRA 703 G.R. No. 105371 November 11, 1993 Facts: The Philippine Postal Corporation issued circular No. 92-28 to implement Section 35 of RA 7354 withdrawing the franking privilege from the SC, CA, RTCs, MeTCs, MTCs and Land Registration Commission and with certain other government offices. It is alleged that RA 7354 is discriminatory becasue while withdrawing the franking privilege from judiciary, it retains the same for the President & Vice-President of the Philippines, Senator & members of the House of Representatives, COMELEC, National Census & Statistics Office and the general public. The respondents counter that there is no discrimination because the law is based on a valid classification in accordance with the equal protection clause. Issue: Whether or Not Section 35 of RA 7354 is constitutional. Held: The equal protection of the laws is embraced in the concept of due process, as every unfair discrimination offends the requirements of justice and fair play. It has nonetheless been embodied in a separate clause in Article III Section 1 of the Constitution to provide for amore specific guarantee against any form of undue favoritism or hostility from the government. Arbitrariness in general may be challenged on the basis of the due process clause. But if the particular act assailed partakes of an unwarranted partiality or prejudice, the sharper weapon to cut it down is the equal protection clause. Equal protection simply requires that all persons or things similarly situated should be treated alike, both as to rights conferred and responsibilities imposed. What the clause requires is equality among equals as determined according to a valid classification. Section 35 of RA 7354 is declared unconstitutional. Circular No. 92-28 is set aside insofar

Facts: The main target of this petition is Section 35 of R.A. No. 7354 as implemented by the Philippine Postal Corporation through itsCircular No. 92-28. These measures withdraw the franking privilege from the SC, CA, RTC, MTC, MeTC and the Land RegistrationCommission and its Registers of Deeds, along with certain other government offices. The petitioners are members of the lower courts who feel that their official functions as judges will be prejudiced by the above-named measures. The petition assails the constitutionality of R.A. No. 7354. Issues:

No. 7354 is entitled "An Act Creating the Philippine Postal Corporation. Defining its . It is the submission of the petitioners that Section 35 of R. (3) Whether or not it is discriminatory and encroaches on the independence of the Judiciary Held: (1) Article VI.(1) Whether or not its title embraces more than one subject and does not express its purpose (2) Whether or not it did not pass the required readings in both Houses of Congress and printed copies of the bill in its final form were not distributed among the members before its passage. Sec. through such publication of legislative proceedings as is usually made. if they shall so desire. in order that they may have opportunity of being heard thereon. and (3) to fairly apprise the people. by petition or otherwise. of the subject of legislation that is being considered. (2) to prevent surprise or fraud upon the legislature by means of provisions in bills of which the title gives no intimation. of the Constitution providing that "Every bill passed by the Congress shall embrace only one subject which shall be expressed in the title thereof. 26(l). No. and which might therefore be overlooked and carelessly and unintentionally adopted.A.A. 7354 which withdrew the franking privilege from the Judiciary is not expressed in the title of the law. R. nor does it reflect its purposes." The purposes of this rule are: (1) to prevent hodge-podge or "log-rolling" legislation.

Thereafter. The withdrawal of the franking privilege from some agencies is germane to the accomplishment of the principal objective of R. and it is the subject. and reasonably covers all the provisions of the act. or to be as comprehensive as to cover every single detail of the measure. which is required to be briefly expressed in its title. Functions and Responsibilities. there is sufficient compliance with the constitutional requirement. The title of the bill is not required to be an index to the body of the act. The reason is that where a statute repeals a former law. It was then presented to and approved by President . not the effect of a law." The petitioners' contention is untenable. the repeal of a statute on a given subject is properly connected with the subject matter of a new statute on the samesubject. such repeal is the effect and not the subject of the statute.Powers. No. It has been held that if the title fairly indicates the generalsubject. the bill was enrolled with its certification by Senate President Neptali A. Furthermore. and is not calculated to mislead the legislature or the people. 7354. notwithstanding that the title is silent on the subject. Providing for Regulation of the Industry and for Other Purposes Connected Therewith.A. which is the creation of a more efficient and effective postal service system. and therefore a repealing section in the new statute is valid. (2) It is a matter of record that the conference Committee Report on the bill in question was returned to and duly approved by both the Senate and the House of Representatives. Gonzales and Speaker Ramon V. Mitra of the House of Representatives as having been duly passed by both Houses of Congress.

The withdrawal of the franking privileges was indeed discriminatory. it retains the same for the President of the Philippines. PRADO .A. the remedy is to withdraw it altogether from all agencies of government. which definitely needs it. The classification was not based on substantial distinctions. PHILIPPINE JUDGES ASSOCIATION vs. (3) It is alleged that R. Senators and Members of the House of Representatives. The problem is not solved by retaining it for some and withdrawing it from others. the National Census and Statistics Office. No.A case digest . 7354 is discriminatory because while withdrawing the franking privilege from the Judiciary. 1992. the Vice President of the Philippines. especially where there is no substantial distinction between those favored. including those who do not need it. which may or may not need it at all. Aquino on April 3. the Commission on Elections. and the Judiciary.Corazon C. If the problem of the respondents is the loss of revenues from the franking privilege. Under the doctrine of separation powers. former Presidents of the Philippines. and the general public in the filing of complaints against public offices and officers. The problem is not solved by violating the Constitution. The enrolled bill is conclusive upon the Judiciary (except in matters that have to be entered in the journals like the yeas and nays on the final reading of the bill). the Court may not inquire beyond the certification of the approval of a bill from the presiding officers of Congress.

In addition. or to be as comprehensive as to cover every single detail of the measure. It is not based on substantial distinctions that make real differences between the Judiciary and the grantees of the franking privilege. The distinction made by the law is superficial. and the vote thereon shall be taken immediately thereafter. . MTC." . . MTCC. Republic Act 7354 was passed into law stirring commotions from the Judiciary. PETE PRADO Direct Filing Facts. COA. Upon the last reading of a bill. Issues. no amendment thereto shall be allowed.Violative of Art VI Sec 26(2) which says 'No bill passed by either House shall become a law unless it has passed three readings on separate days. vs.Violative of the Equal protection clause Ruling: The Supreme Court sustained as to the violation of Art VI Sec 26(1) ruling further that it's adoption is within the terms prescribed by law saying that the title of the bill is not required to be an index to the body of the act. ET AL. However. Therefore. and the yeas and nays entered in the Journal. Sec 35 was ruled out to be in violation of the equal protection clause. except when the President certifies to the necessity of its immediate enactment to meet a public calamity or emergency. WON RA 7354 is unconstitutional.Violative of Art VI Sec 26(1) which says '"Every bill passed by the Congress shall embrace only one subject which shall be expressed in the title thereof. and other government offices were withdrawn from them. RA 7354 is declared UNCONSTITUTIONAL. The franking privelege of the Supreme Court.92-28.PHILIPPINE JUDGES ASSOCIATION. the petitioners raised the issue of constitutionality and the methods adopted prior it becoming a law. . Under its Sec 35 as implemented by Philippine Postal Corporation through its Circular No. and printed copies thereof in its final form have been distributed to its Members three days before its passage. RTCs.

bills authorizing increase of the public debt. VI. respectively. but the Senate may propose or concur with amendments. no amendment thereto shall be allowed. and the yeas and nays entered in the Journal. VI. HELD No.R. otherwise known as the Expanded Value-Added Tax Law. bills of local application. 11197 and SB. Secretary of Finance By: Dennis D. and printed copies thereof in its final form have been distributed to its Members three days before its passage. Section 26(2) of the Constitution. ISSUE Whether or not RA 7716 violated Art. is an act that seeks to widen the tax base of the existing VAT system and enhance its administration by amending the National Internal Revenue Code. San Diego G. Upon the last reading of a bill. 115455 235 SCRA 630 (1994) FACTS RA 7716. It is sufficient that the House of Representatives initiated the passage of the bill which may undergo extensive changes in the Senate. No. Section 24: All appropriation. and private bills shall originate exclusively in the House of Representatives. . Sections 24 and 26(2) of the Constitution. Art. 1630. No. Section 26(2): No bill passed by either House shall become a law unless it has passed three readings on separate days. The phrase “originate exclusively” refers to the revenue bill and not to the revenue law. except when the President certifies to the necessity of its immediate enactment to meet a public calamity or emergency. Art. and the vote thereon shall be taken immediately thereafter. revenue or tariff bills. No. There are various suits questioning and challenging the constitutionality of RA 7716 on various grounds. No. 1630 and it did not pass three readings on separate days on the Senate thus violating Article VI. having been certified as urgent by the President need not meet the requirement not only of printing but also of reading the bill on separate days. VI. Section 24 and Art.Tolentino vs. SB. Tolentino contends that RA 7716 did not originate exclusively from the House of Representatives but is a mere consolidation of HB. VI.

it is not the law but the revenue bill which is required by the Constitution to originate exclusively in the House of Representatives. tariff or tax bills.R. VI. 1630 did not pass 3 readings as required by the Constitution. because it is in fact the result of the consolidation of 2 distinct bills. Sec. August 25. 24 and 26(2) of the Constitution Held: The argument that RA 7716 did not originate exclusively in theHouse of Representatives as required by Art. To begin with. No. private bills and bills of local application must come from . Political Law Facts: The value-added tax (VAT) is levied on the sale. 1994 Sunday. 2009 Posted by Coffeeholic Writes Labels: Case Digests. 24 of the Constitution will not bear analysis. January 25. RA 7716 seeks to widen the tax base of the existing VAT system and enhance its administration by amending the National Internal Revenue Code. Indeed. what the Constitution simply means is that the initiative for filingrevenue. No. There is also a contention that S. No. To insist that a revenue statute and not only the bill which initiated the legislative process culminating in the enactment of the law must substantially be the same as the House bill would be to deny the Senate’s power not only to concur with amendments but also to propose amendments. VI. Secretary of Finance G. VI. No. 115455.Tolentino vs. 24 of the Constitution. bills authorizing an increase of the public debt. barter or exchange of goods and properties as well as on the sale or exchange of services. 11197 and S. Issue: Whether or not RA 7716 violates Art. 1630. There are various suits challenging the constitutionality of RA 7716 on various grounds. Secs. One contention is that RA 7716 did not originate exclusively in theHouse of Representatives as required by Art. Sec. H.

elected as they are from the districts. In March 1994. Eventually. the members of the House can be expected to be more sensitive to the local needs and problems. No. so long as action by the Senate as a body is withheld pending receipt of the House bill. The next argument of the petitioners was that S. HB 8817 became a law (RA 7720). In May 1993. That upon the certification of a bill by the President the requirement of 3 readings on separate days and of printing and distribution can be dispensed with is supported by the weight of legislative practice. In February 1994. Nor does the Constitution prohibit the filing in the Senate of a substitute bill in anticipation of its receipt of the bill from the House. In January 1994. HB 8817 (An Act Converting the Municipality of Santiago into an Independent Component City to be known as the City of Santiago) was passed in the HOR. the HB 8817 was transmitted to the Senate. a Senate bill (SB 1243) of similar title and content with that of HB 8817 was introduced in the Senate. 1630 did not pass 3 readings on separate days as required by the Constitution because the second and third readings were done on the same day. Alvarez vs Guingona on June 23. the Senate conducted a public hearing on SB 1243. 1630 as urgent. 2011 Municipal Corporation – LGU Requirement – Income – Inclusion of IRAs In April 1993. the Senate Committee on Local Government rolled out its recommendation for approval of HB 8817 as it was totally the same with SB 1243. But this was because the President had certified S. The presidential certification dispensed with the requirementnot only of printing but also that of reading the bill on separate days. Now Alvarez et al are assailing the constitutionality of the said law on the ground that the bill creating the law did not originate from the lower house and that the Santiago was not able to comply with the income .theHouse of Representatives on the theory that. No.

of at least P20M per annum in order for it to be a city.” was filed in the House of Representatives. 2. That in the computation of the reported average income of P20. The Senate only conducted its 1st hearing on the said SB one month after the HB was transmitted to the Senate (in anticipation of the said HB as well). a counterpart of HB No. The IRAs are items of income because they form part of the gross accretion of the funds of the local government unit. On March 22. The house bill was filed first before the senate bill as the record shows. NO. the House of Representatives. 1993. 1994. 2. to classify the same as a special fund or transfer. Meanwhile. upon being apprised of the action of the Senate. entitled “An Act Converting the Municipality of Santiago into an Independent Component City to be known as the City of Santiago. Further. too. NO.581. YES. 1243. To reiterate.R. was filed in the Senate. ISSUES: 1. ALVAREZ V. Whether or not the IRA should be included in the computation of an LGU’s income. Whether or not RA 7720 is invalid for not being originally from the HOR. 8817. 8817. approved the amendments proposed by the Senate. The IRA should be added in the computation of an LGU’s average annual income as was done in the case at bar. GUINGONA – G. 2nd and 3rd reading in the HOR. its instrumentalities and government-owned-or-controlled corporations. nil is there a basis. Senate Bill No. since IRAs have a technical definition and meaning all its own as used in the Local Government Code that unequivocally makes it distinct from special funds or transfers referred to when the Code speaks of “funding support from the national government.974. HB No. 118303 – 252 SCRA 695 Facts: On April 18. recurring item of income. They thus constitute income which the local government can invariably rely upon as the source of much needed funds. the Senate held in abeyance any hearing on the said SB while the HB was on its 1 st. The IRAs regularly and automatically accrue to the local treasury without need of any further action on the part of the local government unit. IRAs are a regular. HELD: 1. Issue: .97 included the IRA which should not be.

Jr. The filing in the Senate of a substitute bill in anticipation of its receipt of the bill from the House. 1243. Petitioners contend that since a bill of the same import was passed in the Senate. Alvarez v. 7720 be said to have originated in the House of Representatives as required? Held: Yes. No. A counterpart of HB 8817. Facts: HB 8817. When a plebiscite on the Act was held on July 13. and was transmitted to the Senate 28 Jan 1994. 8817 was filed in the House of Representatives first before SB No. and was passed as well. a great majority of the registered voters of Santiago voted in favor of the conversion of Santiago into a city. SB No. its own version of HB 8817. it cannot be said to have originated in the House of Representatives.. 7720 did not originate exclusively in the House of Representatives because a bill of the same import. 1243.” was filed in the House of Representatives. Issue: whether or not considering that the Senate passed SB 1243. The enrolled bill was submitted to and signed by the Chief Executive as RA 7720. The HB was approved on third reading 17 Dec. SB 1243 was filed in the Senate.R. Guingona G. 1996 Hermosisima. was passed in the Senate. for as long as the Senate does not act thereupon until it receives the House bill. Bills of local application are required to originate exclusively in the House of Representatives. 8817. J. 1243 was filed in the Senate. and transmitted to the Senate. entitled “An Act Converting the Municipality of Santiago into an Independent Component City to be known as the City of Santiago. subsequently passed by the House of Representatives. does not contravene the constitutional requirement that a bill of local application should originate in the House of Representatives. Such is untenable because it cannot be denied that the HB was filed first (18 Apr 1993). .Does the passing of SB No. RA 7720 can be said to have originated in the House of Representatives Held: Yes. The SB was filed 19 May. 1994. the claim of petitioners that Republic Act No. Although a bill of local application should originate exclusively in the House of Representatives. into Republic Act No. is untenable because it cannot be denied that HB No. 118303 January 31. the Senate’s own version of HB No.

Nor does the Constitution prohibit the filing in the Senate of a substitute bill in anticipation of its receipt of the bill from the House. bills authorizing an increase of the public debt. for as long as the Senate does not act thereupon until it receives the House bill. Secretary of Finance. tariff. April 08. elected as they are from the districts. The filing in the Senate of a substitute bill in anticipation of its receipt of the bill from the House of Representatives. He filed an action for mandamus to compel the DND and AFP to reinstate him to active service and readjust his rank and pay emoluments. . the Court said that what the Constitution simply means is that the initiative for filing revenue. are expected to approach the same problems from the national perspective. Mata Post under case digests. or tax bills. private bills and bills of local application must come from the House of Representatives on the theory that. the AFP and DND contend that the said provision of RA 1600 has no relevance or pertinence to the budget in question or to any appropriation item therein. does not contravene the constitutional requirement that a bill of local application should originate in the House of Representatives. Garcia claims that his reversion to inactive status is violation of RA 1600 which prohibits the reversion of officers with at least 10 years of service. 2012 Posted by Schizophrenic Mind Facts: Garcia was a reserve officer on active duty who wasreversed to inactive status. the members of the House can be expected to be more sensitive to the local needs and problems. Garcia vs.The filing in the Senate of a substitute bill in anticipation of its receipt of the bill from the House. On the other hand. for as long as the Senate does not act thereupon until it receives the House bill. Political Law at Sunday. does not contravene the constitutional requirement that a bill of local application should originate in the House of Representatives. who are elected at large. On the other hand. (RA 1600 was an appropriation law for 1956-57). In Tolentino v. the senators. so long as action by the Senate as a body is withheld pending receipt of the House bill. Both views are thereby made to bear on the enactment of such laws.

Garcia cannot compel the AFP to reinstate him. The subject to be considered must be expressed in the title of the act. Section 11 of RA 1600 fails to disclose the relevance to any appropriation item. When an act contains provisions which are clearly not embraced in the subject of the act. as expressed in the title. It also violates the rule on one-bill. It was indeed a new and completely unrelated provision attached to the GAA.Issue: Whether RA 1600 is valid? Does it contain rider in an appropriation bill? Held: The incongruity and irrelevancy are already evident. Hence it was A NON-APPROPRIATION ITEM INSERTED IN AN APPROPRIATION MEASURE. 2012 Political Law – Salaries of the Members of Congress – Other Emolument . Philippine Constitution Association vs Gimenez on January 2. one subject. such provisions are void. in violation of the constitutionalprohibition against RIDERS to the general appropriation act. inoperative and without effect. SECTION 11 is unconstitutional. RA 1600 is an appropriation law for the operation of government while Section 11 refers to a fundamental governmental policy of calling to active duty and the reversion of inactive statute of reserve officers in the AFP.

receive an annual compensation of seven thousand two hundred pesos each. The same provision constitutes “selfish class legislation” because it allows members and officers of Congress to retire after twelve (12) years of service and gives them a gratuity equivalent to one year salary for every four years of service. which. the President of the Senate and the Speaker of the House of Representatives shall each receive an annual compensation of sixteen thousand pesos. insofar as members of Congress are concerned. and to the elective officials of both Houses (of Congress). Until otherwise provided by law. The Sol-Gen counter argued alleging that The grant of retirement or pension benefits under Republic Act No. when attending sessions of the Congress. of the Constitution. therefore.Philippine Constitution Association. ISSUE: Whether or not RA 3836 is constitutional. is another attempt of the legislator to further increase their compensation in violation of the Constitution. No increase in said compensation shall take effect until after the expiration of the full term of all the Members of the Senate and of the House of Representatives approving such increase. in any case. Article VI. cannot exceed 24 months. which reads: “The senators and the Members of the House of Representatives shall. including per diems and other emoluments or allowances. contrary to the provisions of Article VI. and exclusive only of travelling expenses to and from their respective district in the case of Members of the House of Representatives and to and from their places of residence in the case of Senators. The payment of commutable vacation and sick leave benefits under the said Act is merely “in the nature of a basis for computing the gratuity due each retiring member” and. is not an indirect scheme to increase their salary. 3836 to the officers objected to by the petitioner does not constitute “forbidden compensation” within the meaning of Section 14 of Article VI of the Philippine Constitution. commutable at the highest rate received. Section 14 of the Constitution. The law in question does not constitute class legislation. which is not refundable in case of reinstatement or re election of the retiree. The provision on retirement gratuity is an attempt to circumvent the Constitutional ban on increase of salaries of the members of Congress during their term of office. HELD: Section 14. Inc (PHILCONSA) assails the validity of RA 3836 insofar as the same allows retirement gratuity and commutation of vacation and sick leave to Senators and Representatives. The provision on vacation and sick leave.” . unless otherwise provided by law. while all other officers and employees of the government can retire only after at least twenty (20) years of service and are given a gratuity which is only equivalent to one month salary for every year of service.

No. Article VI.000.When the Constitutional Convention first determined the compensation for the Members of Congress. without awaiting the expiration of the full term of all the Members of the Senate and the House of Representatives approving such increase. the amount fixed by it was only P5.00 per annum but it embodies a special proviso which reads as follows: “No increase in said compensation s hall take effect until after the expiration of the full term of all the members of the National Assembly elected subsequent to approval of such increase. This is the pivotal point on this fundamental question as to whether the retirement benefit as provided for in Republic Act 3836 fall within the purview of the term “other emoluments. 2009 Posted by Coffeeholic Writes Labels: Case Digests. as salary. Retirement were immediately available thereunder. under the original constitutional provision regarding the power of the National Assembly to increase the salaries of its members. 18 Jun 1987] Friday. which was on June 22. TIO VS. Such provision clearly runs counter to the prohibition in Article VI. to take effect upon the approval of said Act.” “Emolument” as “the profit arising from office or employment. Section 14 of the Constitution. 1987. L-75697. Political Law Facts: The case is a petition filed by petitioner on behalf of videogram operators adversely affected by Presidential Decree No. 1963.” It is evident that retirement benefit is a form or another species of emolument. January 30.R. G. that which is received as compensation for services or which is annexed to the possession of an office. includes in the term compensation “other emoluments”. no increase would take effect until after the expiration of the full term of the members of the Assembly elected subsequent to the approval of such increase. RA 3836 is hereby declared unconstitutional by the SC. because it is a part of compensation for services of one possessing any office.” In other words. VIDEOGRAM REGULATORY BOARD [151 SCRA 208. The Constitutional provision in the aforementioned Section 14. “An Act Creating the Videogram Regulatory Board" with broad powers to regulate . Republic Act 3836 provides for an increase in the emoluments of Senators and Members of the House of Representatives. fees and perquisites.

and the other fifty percent (50%) shall accrue to the municipality where the tax is collected.and supervise the videogram industry. thereby resulting in substantial losses estimated at P450 Million annually in government revenues. A month after the promulgation of the said Presidential Decree. Lease or Disposition of Videograms. among others. have greatly prejudiced the operations of movie houses and theaters. — There shall be collected on each processed videotape cassette." — tapes shall be subject to "Section 10. ready for playback. That in Metropolitan Manila. PROVIDED. That locally manufactured or imported sales blank video tax. Video Tapes. an annual tax of five pesos. the provinceshall collect a tax of thirty percent (30%) of the purchase price orrental rate. the tax shall be shared equally by the City/Municipality and the Metropolitan Manila Commission. contractor's specific. the amended the National Internal Revenue Code provided that: "SEC. regardless of length. for every sale. discs. Tax on Sale. amusement and other taxes. 134.” The rationale behind the tax provision is to curb the proliferation and unregulated circulation of videograms including. as the case may be. Such unregulated circulation have caused a sharp decline in theatrical attendance by at least forty percent (40%) and a tremendous drop in the collection of sales. Videogram(s) establishments collectively earn around P600 Million per . cassettes or any technical improvement or variation thereof. Notwithstanding any provision of law to the contrary.” “Fifty percent (50%) of the proceeds of the tax collected shall accrue to the province. lease or disposition of a videogram containing a reproduction of any motion picture or audiovisual program. Provided. videotapes.

(2) Whether or nor the DECREE is constitutional. We find no clear violation of the Constitution which would justify us in pronouncing Presidential Decree No. and the proliferation of pornographicvideo tapes. sales and disposition of videograms. the tax remains a valid imposition. the flagrant violation of intellectual property rights. The unregulated activities of videogram establishments have also affected the viability of the movie industry. While the underlying objective of the DECREE is to protect the moribund movie industry. particularly because of the rampant film piracy. And while it was also an objective of the DECREE to protect the movie industry. The levy of the 30% tax is for a public purpose. Held: Taxation has been made the implement of the state's police power. thereby depriving the Government of approximately P180 Million in taxes each year. 1987 as unconstitutional and void.annum from rentals. and these earnings have not been subjected to tax. and losses in government revenues due to the drop in theatrical attendance. considering "the unfair competition posed by rampant film piracy. not to . Issues: (1) Whether or not tax imposed by the DECREE is a valid exercise of police power. there is no question that public welfare is at bottom of its enactment. It was imposed primarily to answer the need for regulating the video industry. the erosion of the moral fiber of the viewing public brought about by the availability of unclassified and unreviewedvideo tapes containing pornographic films and films with brutally violent sequences.

As a tool for regulation it is simply one of the regulatory and control mechanisms scattered throughout the decree. On November 5. Petitioner on his own behalf and purportedly on behalf of other videogram operators adversely affected assailed the constitutionality of PD 1987 entitled "An Act Creating the Videogram Regulatory Board" with broad powers to regulate and supervise the videogram industry. The express purpose of PD 1987 to include taxation of the video industry in order to regulate and rationalize the heretofore uncontrolled distribution of videos is evident from Preambles 2 and 5. the general object of the decree. 1987 Melencio-Herrera. The tax provision is not inconsistent with nor foreign to the general subject and title. The title of the decree. which is the regulation of the video industry through the VRB as expressed in its title. fifteen (15) days after completion of its publication in the Official Gazette.: Facts: 1. 3.Petitioner's contended that the tax provision of the decree is a rider. J. PD 1994 amended the NIRC. The Decree promulgated on October 5. 1985. which calls for the creation of the VRB is comprehensive enough to include the purposes expressed in its Preamble and reasonably covered all its provisions.R." WHEREFORE. Those preambles explain the motives of the lawmaker in presenting the measure. No costs. No. It is unnecessary to express all those objectives in the title or that the latter be an index to the body of the decree.mention the fact that the activities of video establishments are virtually untaxed since mere payment of Mayor's permit and municipal license fees are required to engage in business. The foregoing provision is allied and germane to. 2. 2. 1985. a month after the promulgation of the decree. Tio v Videogram Digest Tio v Videogram G. the instant Petition is hereby dismissed. took effect on April 10. 1986. . L-75697 June 18. ISSUE: Whether or not the PD 1987 is unconstitutional PD 1987 constitutional. 1. and is reasonably necessary for the accomplishment of.

Sign up to vote on this title
UsefulNot useful