Political Law

Valentin Tio vs Videogram Regulatory Board

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G.R. No. L-75697 – 151 SCRA 208 – Political Law – Constitutional Law – The Legislative Department – Legislative Powers; Lawmaking Power – The Title of the Law Must Embrace Only One Subject

Delegation of Power – Delegation to Administrative Bodies

In 1985, Presidential Decree No. 1987 entitled An Act Creating the Videogram Regulatory Board was enacted which gave broad powers to the VRB to regulate and supervise the videogram industry. The said law sought to minimize the economic effects of piracy. There was a need to regulate the sale of videograms as it has adverse effects to the movie industry. The proliferation of videograms has significantly lessened the revenue being acquired from the movie industry, and that such loss may be recovered if videograms are to be taxed. Section 10 of the PD imposes a 30% tax on the gross receipts payable to the LGUs.

In 1986, Valentin Tio assailed the said PD as he averred that it is unconstitutional on the following grounds:

1. Section 10 thereof, which imposed the 30% tax on gross receipts, is a rider and is not germane to the subject matter of the law.

2. There is also undue delegation of legislative power to the VRB, an administrative body, because the law allowed the VRB to deputize, upon its discretion, other government agencies to assist the VRB in enforcing the said PD.

ISSUE: Whether or not the Valentin Tio’s arguments are correct.


1. The Constitutional requirement that “every bill shall embrace only one subject which shall be expressed in the title thereof” is sufficiently complied with if the title is comprehensive enough to include the general purpose which a statute seeks to achieve. In the case at bar, the questioned provision is allied and germane to, and is reasonably necessary for the accomplishment of, the general object of the PD, which is the regulation of the video industry through the VRB as expressed in its title. The tax provision is not inconsistent with, nor foreign to that general subject and title. As a tool for regulation it is simply one of the regulatory and control mechanisms scattered throughout the PD.

2. There is no undue delegation of legislative powers to the VRB. VRB is not being tasked to legislate. What was conferred to the VRB was the authority or discretion to seek assistance in the execution, enforcement, and implementation of the law. Besides, in the very language of the decree, the authority of the BOARD to solicit such assistance is for a “fixed and limited period” with the deputized agencies concerned being “subject to the direction and control of the [VRB].”

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