Political Law

Santiago Alalayan vs National Power Corporation

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G.R. No. L-24396 – 24 SCRA 172 – Political Law – Constitutional Law – The Legislative Department – Legislative Powers; Lawmaking Power – Title of the Law Must Express One Subject

In 1961, Republic Act No. 3043 (An Act to Further Amend Commonwealth Act Numbered One Hundred Twenty, as Amended by Republic Act Numbered Twenty Six Hundred and Forty One) was passed. This law amended the charter of  NAPOCOR (National Power Corporation). Section 3 of RA 3043 provides that:

a. contractors being supplied by NAPOCOR shall not exceed an annual profit of 12%;

b. if they do, they shall refund such excess to their customers;

c. that NAPOCOR has the power to renew all existing contracts with franchise holders for the supply of energy.

Santiago Alalayan and the Philippine Power and Development Company (PPDC) assailed the said provision. They averred that Section 3 is a rider because first, it was not included in the title of the amending law nor was it included in the amended law. Second, the main purpose of RA 3043 was to increase the capital stock of NAPOCOR hence Alalayan et al believed that Section 3 was not germane to RA 3043.

ISSUE: Whether or not Section 3 of RA 3043 is constitutional.

HELD: Yes. The Supreme Court simply ruled that the Constitution does not require Congress to employ in the title of an enactment, language of such precision as to mirror, fully index or catalogue all the contents and the minute details therein. It suffices if the title should serve the purpose of the constitutional demand that it inform the legislators, the persons interested in the subject of the bill, and the public, of the nature, scope and consequences of the proposed law and its operation. And this, to lead them to inquire into the body of the bill, study and discuss the same, take appropriate action thereon, and, thus, prevent surprise or fraud upon the legislators.

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