G.R. No. L-14542 – 6 SCRA 418 – Political Law – Constitutional Law – One Title One Subject Rule – Tenancy Act
Manuel Cordero was the trial attorney of the Tenancy Counsel Unit (TCU) of the Agricultural Tenancy Commission of the Department of Justice. He later appeared as the counsel of indigent tenant Vicente Salazar who filed a case against landlord Leonardo Sta. Romana in order to reinstate and reliquidate past harvests. Sta. Romana filed a motion to disqualify Cordero as counsel for Salazar and he invoked Sec. 54 of Republic Act No. 1199 or The Agricultural Tenancy Act of the Philippines. The said section indicates that representation by counsel of tenants who cannot afford to pay should be done by the public defenders of the Department of Labor.
Judge Jose Cabatuando ruled in favor of Sta. Romana. Cordero appealed. During pendency of the appeal Republic Act No. 2263, AN ACT AMENDING CERTAIN SECTIONS OF REPUBLIC ACT NUMBERED ONE THOUSAND ONE HUNDRED NINETY-NINE, OTHERWISE KNOWN AS THE AGRICULTURAL TENANCY ACT OF THE PHILIPPINES, was passed. This law, particularly Sections 19 and 20 thereof, amended the previous law and now allows trial lawyers from the TCU to represent indigent tenants and it is also the basis of the creation of the Tenancy Mediation Division. Cordero filed a Manifestation averring that by virtue of the amendment the issue has now become moot and academic. The Solicitor General argued that the provisions were not embraced in the title of the amending law nor in the amended law hence void.
ISSUE: Whether or not the creation of the TMD is embraced in the title of the bill and whether or not to allow trial lawyers from TCU to appear as counsel for indigent tenants should be allowed.
HELD: Yes. The Supreme Court ruled that that the constitutional requirement in question is satisfied if all parts of the law are related, and are germane to the subject matter expressed in the title of the bill. The constitutional requirement is complied with as long as the law, as in the instant case, 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. To declare sections 19 and 20 of RA 2263 null and void would in effect upset the transfer of the duty of representing indigent tenants from the public defenders of the Department of Labor to the trial attorneys in the Mediation Division of the Agricultural Tenancy Commission of the Department of Justice. In other words, a declaration of nullity of these provisions of RA 2263 would do harm to, and would be nugatory of, the intention of Congress to consolidate the function of enforcing our tenancy laws in the Department of Justice.