THE PHILIPPINE JUDGES ASSOCIATION, duly rep. by its President, BERNARDO P. ABESAMIS, Vice-President for Legal Affairs, MARIANO M. UMALI, Director for Pasig, Makati, and Pasay, Metro Manila, ALFREDO C. FLORES, and Chairman of the Committee on Legal Aid, JESUS G. BERSAMIRA, Presiding Judges of the…
- G.R. Number: G.R. No. 105371
- Promulgated: 1993-11-11
- Ponente: Cruz, J.
Doctrine
A provision of law may be sustained against title-and-procedure attacks even while a specific section is struck down for violating equal protection.
The Court recognizes it may face criticism for decisions perceived as self-serving, but must decide cases according to law and conscience.
Facts
Petition challenged R.A. No. 7354 and related administrative circular withdrawing franking privilege from certain courts and offices.
The Court reviewed attacks that the subject of R.A. No. 7354 was not expressed in its title and that it was not passed according to prescribed procedure.
The Court annulled Section 35 of R.A. No. 7354 as violative of equal protection under Article III, Sec. 1 of the Constitution.
Circular No. 92-28 was set aside insofar as it withdrew the franking privilege from the Supreme Court, Court of Appeals, Regional Trial Courts, Municipal Trial Courts, and the National Land Registration Authority and its Registers of Deeds; the franking privilege was restored and the temporary restraining order dated 2 June 1992 was made permanent.
Issues
Whether R.A. No. 7354 is invalid because its subject is not expressed in its title or because it was not passed in accordance with the prescribed procedure.
Whether Section 35 of R.A. No. 7354 violates the equal protection clause of Article III, Sec. 1 of the Constitution.
Whether Circular No. 92-28 validly withdrew the franking privilege from specified courts and offices.
Ruling
The Court sustained R.A. No. 7354 against the attack that its subject was not expressed in its title and that it was not passed in accordance with prescribed procedure.
Section 35 of R.A. No. 7354 was annulled as violative of the equal protection clause (Art. III, Sec. 1).
Circular No. 92-28 was set aside insofar as it withdrew the franking privilege from the named courts and offices; the franking privilege was restored and the TRO of 2 June 1992 was made permanent.
Keywords
G.R. No. 105371, Republic Act No. 7354, independence of the Judiciary, franking privilege, Article VI, Section 26(1) of the Constitution, constitutionality of statutes, one subject rule, hodge-podge or log-rolling legislation, Philippine Postal Corporation Circular No. 92-28, repealing clause, Commonwealth Act No. 265, Republic Act No. 69, Republic Act No. 180, Republic Act No. 1414, Republic Act No. 2087, Republic Act No. 5059, National Land Registration Authority, judicial proceedings, Southern Pac. Co. v. Bartine, 170 Fed. 725, title