ALALAYAN vs.

NATIONAL POWER CORPORATION

G.R. No. L-24396 | July 29, 1968
Fernando, J.

Topic: Subject and title of bills - general prohibition of “riders” (Par. 1)

SANTIAGO P. ALALAYAN, ET AL., suing in his behalf and for the benefit of all other persons
having common or general interest with him in accordance with Sec. 12, Rule 3, Rules of Court,
vs. NATIONAL POWER CORPORATION and ADMINISTRATOR OF ECONOMIC
COORDINATION

Facts
In 1961, Republic Act No. 3043 (An Act to Further Amend Commonwealth Act Numbered One
Hundred Twenty, as Amended by Republic Act Numbered Twenty Six Hundred and Forty One)
was passed. This law amended the charter of NAPOCOR (National Power Corporation).
Section 3 of RA 3043 provides that:
a. contractors being supplied by NAPOCOR shall not exceed an annual profit of 12%;
b. if they do, they shall refund such excess to their customers;
c. that NAPOCOR has the power to renew all existing contracts with franchise holders for the
supply of energy.
Santiago Alalayan and the Philippine Power and Development Company (PPDC) assailed that
Section 3 is a rider because first, it was not included in the title of the amending law nor was it
included in the amended law. Second, the main purpose of RA 3043 was to increase the capital
stock of NAPOCOR hence Alalayan et al believed that Section 3 was not germane to RA 3043.

Issue
Whether or not Section 3 of RA 3043 is constitutional.

Held
Yes. The Supreme Court simply ruled that 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.