Cordero vs. Hon. Cabatuando Digest

Cordero v. Hon. Cabatuando Case No. 81 G.R. No. L-14542 (October 31, 1962) Chapter I, Page 12, Footnote No.47 FACTS: Republic Act No. 1199 is the Agricultural Tenancy Act of the Philippines. Section 54 of this act expressed that indigent tenants should be represented by Public Defendant of Department of Labor. Congress then amended this in Republic Act No. 2263: “An Act Amending Certain Sections of Republic Act No. 1199.” Section 19 of the amendatory act says that mediation of tenancy disputes falls under authority of Secretary of Justice. Section 20 also provides that indigent tenants shall be represented by trial attorney of the Tenancy Mediation Commission. ISSUE: W/N Sections 19 and 20 of Rep. Act No. 2263 is unconstitutional because of the constitutional provision that “No bill which may be enacted into law shall embrace more than one subject which shall be expressed in the title of the bill.” HELD: Sections 19 and 20 are constitutional. The constitutional requirement is complied with as long the law has a single general subject, which is the Agricultural Tenancy Act, and the amendatory provisions no matter how diverse they may be, so long as they are not inconsistent with or foreign to the general subject, will be regarded as valid. Constitutional provisions relating to subject matter and titles of statutes should not be so narrowly construed as to cripple or impede proper legislation.