Philippine Judges Association vs.
Prado
G.R. No. 105371 November 11, 1993
FACTS:
The petitioners have filed a petition with regards to the validity of Sec 35 R.A. No. 7354 due to
its withdrawal of the franking privileges of the Su preme Court, the Court of Appelas, the
Regional Trial , the Metropolitan Trial Courts, the Municipal Trial Courts, and the Land
Registration Commission and its Registers of Deeds, along with certain other government
offices.
The petitioners, who are members of the lower courts, feel as though their official funtions as
judges will be prejudiced by Sec 35 R.A. No. 7354.
The petitioners question the constitutionality of R.A. No. 7354 on the the grounds that: (1) its
title embraces more than one subject and does not express its purposes; (2) it did not pass the
required readings in both Houses of Congress and printed copies of the bill in its final form were
not distributed among the members before its passage; and (3) it is discriminatory and
encroaches on the independence of the Judiciary.
ISSUE:
Whether or not the Sec 35 of R.A. No. 7354 is constitutional
HELD:
The Supreme Court declared the Sec 35 of R.A. No. 7354 as unconstitutional
1. The first the objection based on Article VI, Sec. 26(l), of the Constitution providing that
"Every bill passed by the Congress shall embrace only one subject which shall be
expressed in the title thereof." 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.
We are convinced that the withdrawal of the franking privilege from some agencies is
germane to the accomplishment of the principal objective of R.A. No. 7354, which is the
creation of a more efficient and effective postal service system. Our ruling is that, by
virtue of its nature as a repealing clause, Section 35 did not have to be expressly included
in the title of the said law.
2. The petitioners uphold that the second paragraph of Sec. 35 covering the repeal of the
franking privilege from the petitioners and this Court under E.O. 207, PD 1882 and PD
26 was not included in the original version of Senate Bill No. 720 or House Bill No.
4200. The petitioners also invoke Sec. 74 of the Rules of the House of Representatives,
requiring that amendment to any bill when the House and the Senate shall have
differences thereon may be settled by a conference committee of both chambers.
Under the doctrine of separation powers, the Court may not inquire beyond the
certification of the approval of a bill from the presiding officers of Congress. Casco
Philippine Chemical Co. v. Gimenez7 laid down the rule that the enrolled bill, is
conclusive upon the Judiciary. The journals are themselves also binding on the Supreme
Court. Applying these principles, we shall decline to look into the petitioners' charges
that an amendment was made upon the last reading of the bill that eventually became
R.A. No. 7354 and that copies thereof in its final form were not distributed among the
members of each House.
3. It is alleged that R.A. No. 7354 is discriminatory because while withdrawing the franking
privilege from the Judiciary, it retains for certain offices that need the privileges less than
the Judiciary. The equal protection of the laws is embraced in the concept of due process,
as every unfair discrimination offends the requirements of justice and fair play. It has
nonetheless been embodied in a separate clause in Article III Sec. 1., of the Constitution
to provide for a more, specific guaranty against any form of undue favoritism or hostility
from the government.
The Philippine Postal Corporation was created and established to operate on the purpose
of promoting public service. Among the services it should be prepared to extend is free
carriage of mail for certain offices of the government that need the franking privilege in
the discharge of their own public functions.
We are unable to agree with the respondents that Section 35 of R.A. No. 7354 represents
a valid exercise of discretion by the Legislature under the police power. On the contrary,
we find its repealing clause to be a discriminatory provision that denies the Judiciary the
equal protection of the laws guaranteed for all persons or things similarly situated. The
distinction made by the law is superficial. It is not based on substantial distinctions that
make real differences between the Judiciary and the grantees of the franking privilege.
