2.

There is also undue delegation of legislative power to the VRB, an

administrative body, because the law allowed the VRB to deputize, up
Valentin Tio vs Videogram Regulatory Board
on its discretion, other government agencies to assist the VRB in enfor
151 SCRA 208 cing the said PD.

Facts:

In 1985, Presidential Decree No. 1987 entitled “An Act Creating the Vid ISSUE: Whether or not the Valentin Tio’s arguments are correct.
eogram Regulatory Board” was enacted which gave broad powers to t
he VRB to regulate and supervise the videogram industry. The said la
w sought to minimize the economic effects of piracy. There was a nee HELD: No.
d to regulate the sale of videograms as it has adverse effects to the
1. The Constitutional requirement that “every bill shall embrace only on
movie industry. The proliferation of videograms has significantly lessene
e subject which shall be expressed in the title thereof” is sufficiently co
d the revenue being acquired from the movie industry, and that such
mplied with if the title be comprehensive enough to include the gener
loss may be recovered if videograms are to be taxed. Section 10 of th
al purpose which a statute seeks to achieve. In the case at bar, the q
e PD imposes a 30% tax on the gross receipts payable to the LGUs.
uestioned provision is allied and germane to, and is reasonably necess
ary for the accomplishment of, the general object of the PD, which is
the regulation of the video industry through the VRB as expressed in i
In 1986, Valentin Tio assailed the said PD as he averred that it is unco
ts title. The tax provision is not inconsistent with, nor foreign to that g
nstitutional on the following grounds:
eneral subject and title. As a tool for regulation it is simply one of the
regulatory and control mechanisms scattered throughout the PD.

1. Section 10 thereof, which imposed the 30% tax on gross receipts, is

a rider and is not germane to the subject matter of the law.
2. There is no undue delegation of legislative powers to the VRB. VRB
is not being tasked to legislate. What was conferred to the VRB was t
he authority or discretion to seek assistance in the execution, enforcem
ent, and implementation of the law. Besides, in the very language of t
he decree, the authority of the BOARD to solicit such assistance is for
a “fixed and limited period” with the deputized agencies concerned bei
ng “subject to the direction and control of the VRB".