This case involved a challenge to the constitutionality of RA 1180, known as the An Act to Regulate the Retail Business. The purpose of the law was to prevent non-citizens from having a monopoly on the country's economic life. Lao Ichong filed a case arguing the subject of the law was not expressed in its title, in violation of the Constitution. The Court ruled the title was sufficient and only dealt with one subject, regulating retail business. As the legislators and public were aware of the law's provisions, it did not violate the constitutional requirement that the title express the subject of the bill. The Court upheld the constitutionality of RA 1180.
This case involved a challenge to the constitutionality of RA 1180, known as the An Act to Regulate the Retail Business. The purpose of the law was to prevent non-citizens from having a monopoly on the country's economic life. Lao Ichong filed a case arguing the subject of the law was not expressed in its title, in violation of the Constitution. The Court ruled the title was sufficient and only dealt with one subject, regulating retail business. As the legislators and public were aware of the law's provisions, it did not violate the constitutional requirement that the title express the subject of the bill. The Court upheld the constitutionality of RA 1180.
This case involved a challenge to the constitutionality of RA 1180, known as the An Act to Regulate the Retail Business. The purpose of the law was to prevent non-citizens from having a monopoly on the country's economic life. Lao Ichong filed a case arguing the subject of the law was not expressed in its title, in violation of the Constitution. The Court ruled the title was sufficient and only dealt with one subject, regulating retail business. As the legislators and public were aware of the law's provisions, it did not violate the constitutional requirement that the title express the subject of the bill. The Court upheld the constitutionality of RA 1180.
This case involved a challenge to the constitutionality of RA 1180, known as the An Act to Regulate the Retail Business. The purpose of the law was to prevent non-citizens from having a monopoly on the country's economic life. Lao Ichong filed a case arguing the subject of the law was not expressed in its title, in violation of the Constitution. The Court ruled the title was sufficient and only dealt with one subject, regulating retail business. As the legislators and public were aware of the law's provisions, it did not violate the constitutional requirement that the title express the subject of the bill. The Court upheld the constitutionality of RA 1180.
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ICHONG v.
HERNANDEZ G.R. No. L-7995 | May 31, 1957 | Labrador, J. | Parts of Statues > Title
Petitioner: LAO H. ICHONG, in his own behalf and in behalf of other alien residents, corporations and partnerships adversely affected by RA No. 1180.
Respondent: JAIME HERNANDEZ, Secretary of Finance, and MARCELINO
SARMIENTO, City Treasurer of Manila
SUMMARY/FACTS: The Legislature passed R.A. 1180 (An Act to Regulate the Retail Business). The purpose of the Act was to prevent persons who are not citizens of the PH from having a stranglehold upon the people’s economic life.
Lao Ichong, in his own behalf and behalf of other alien residents, corporations and partnerships affected by the Act, filed an action to declare it unconstitutional.
Petitioner attacks the constitutionality of the Act contending that the subject of the Act is not expressed or comprehended in the title thereof.
In answer, the Solicitor-General and the Fiscal of the City of Manila contend that the Act has only one subject embraced in the title.
DOCTRINE: Section 21 (1) of Article VI: No bill, which may be enacted into law, shall embrace more than one subject, which shall be expressed in the title of the bill.
ISSUE: Whether or not RA 1180 is unconstitutional. – NO.
RULING: The Court finds the enactment of RA 1180 constitutional. RATIO: One purpose of the constitutional directive that the subject of a bill should be embraced in its title is to apprise the legislators of the purposes, the nature and scope of its provisions, and prevent the enactment into law of matters, which have not received the notice, action and study of the legislators or of the public. The legislators took active interest in the discussion of the law, and a great many of the persons affected by the prohibition in the law conducted a campaign against its approval. It cannot be claimed, therefore, that the reasons for declaring the law invalid ever existed. What Section 21(1) of Article VI of the Constitution prohibits is duplicity, that is, if its title completely fails to apprise the legislators or the public of the nature, scope and consequences of the law or its operation
