Case number 76

Atitiw v Zamora, 471 SCRA 329

Facts: Petitioner Nestor Aliliw filed a petition for prohibition, mandamus and
declaratory relief as taxpayers, and officers and members of the units of the
Cordillera Administrative Region (CAR). They sought the declaration of nullity of the
par. 1 of the special provisions of RA No. 8760, or the General Appropriations Act
directing that the appropriation for the CAR shall be spent to wind up its activities
and pay the separation and retirement benefits of all the affected members and
employees.

Issue: Whether or not the par. 1 of the RA No. 8760 or the General
Appropriations Act is unconstitutional, considering that the Constitution provides
that “Every bill passed by the Congress shall embrace only one subject which shall
be expressed in the title thereof”.

Ruling: No, it is constitutional.

Under the Art. 6 Sec 26 states that “Every bill passed by the Congress shall
embrace only one subject which shall be expressed in the title thereof.”

In this case, an appropriations bill covers a broader range of subject matter

and therefore includes more details compared to an ordinary bill. The title of an
appropriations bill cannot be broader as it is since it is not feasible to come out with
a title that embraces all the details included in an appropriation bill.
 Case Number: 77
Tio v VRB GR No. 75697 June 18, 1987

Facts: The petitioner Valentin Tio through his petition assails the
constitutionality of PD. 1987 entitled “An Act Creating the Videogram Regulatory
Board”. He argued that Sec 10 of PD 1987, imposes a tax of 30% on the gross
receipts payable to the local government is a rider and the same is not germane to
the subject matter thereof.

Issue: Whether or not the PD 1987 or the “Act Creating the Videogram
Regulatory Board” is constitutional, considering that under the law “Every bill
passed by the Congress shall embrace only one subject which shall be expressed in
the title thereof.

Ruling: Yes it is constitutional.

Art. 6 Sec 26 states that “Every bill passed by the Congress shall
embrace only one subject which shall be expressed in the title thereof.

In this case, the said tax provision is germane to and is reasonably

necessary for the accomplishment of, the general object of the PD 1987 which is the
regulation the video industry. It is not inconsistent to that subject and title.
 Case number: 78
Philippine Judges Association v Prado GR No. 105371 Nov. 11,1993

Facts: The RA 7354 implemented the Philippine Postal Corporation to

withdraw the franking privileges or the privilege granting government agencies to
make use of the PPC services free of charge. The petitioners argued the
constitutionality of the second paragraph of Sec 35 because it withdraws the
franking privilege from the Judiciary and is not expressed in the title of the law, nor
does reflect its purposes.

Issue: Whether or not the section 35 of RA 7354 is unconstitutional,

considering that its title embraces more than one subject and does not express its
purposes.

Ruling: Yes it is constitutional.

Art. 6 Sec 26 states that “Every bill passed by the Congress shall
embrace only one subject which shall be expressed in the title thereof.”

In this case, the title of the bill is not required to be an index to the
body of the act or to be as comprehensive as to cover every single detail of the
measure. It has been held that if the title fairly indicates the general subject, and
reasonably covers all the provisions of the act, and is not calculated to mislead the
legislature to the people, there is sufficient compliance with the constitutional
requirement.