Cordero vs. Cabatuando

Sections 19 and 20 of Republic Act No. 2263, which authorized the Secretary of Justice acting through a tenancy mediation division to carry out a national enforcement program including mediation of tenancy disputes and transferred the function of representing indigent tenants to the Department of Justice, are constitutional, because all parts of the law are germane to the single general subject of agricultural tenancy expressed in the title, satisfying the one-subject-one-title requirement of Article VI, Section 21, paragraph 1 of the Philippine Constitution.

The Agricultural Tenancy Commission, operating under the Department of Justice, maintained a Tenancy Counsel Unit within its Mediation Division, staffed by trial attorneys who represented indigent tenants before the Court of Agrarian Relations. The legal basis for this unit was Circular No. 5, dated June 28, 1957, issued by the Agricultural Tenancy Commission and approved by the Secretary of Justice. The basic statute governing agricultural tenancy was Republic Act No. 1199, entitled "The Agricultural Tenancy Act of the Philippines," whose Section 54 originally assigned the duty of representing indigent tenants to public defenders of the Department of Labor. Republic Act No. 2263 later amended certain sections of Republic Act No. 1199, including Sections 53 and 54, transferring the representation function to the trial attorneys of the tenancy mediation commission under the Department of Justice.

On July 21, 1958, the Tenancy Counsel Unit of the Agricultural Tenancy Commission, Department of Justice, through its Trial Attorney Manuel A. Cordero, filed CAR Case No. 1379-NE-58 with the Second Regional District of the Court of Agrarian Relations on behalf of indigent tenant Vicente Salazar against landlord Leonardo Sta. Romana and others, seeking reinstatement and reliquidation of past harvests. In September 1958, respondent landlord Sta. Romana filed a "Motion to Disqualify Counsel and To Set Hearing at Cabanatuan City," praying among other things for the disqualification of Cordero from acting as counsel for the tenant.

Acting on that motion, respondent Judge Jose R. Cabatuando issued an order on September 22, 1958, disqualifying Cordero and any other attorney from the Mediation Division of the Department of Justice from appearing as counsel for Salazar or for any other tenants before the court. The judge upheld the landlord's position on three grounds: first, that representation of tenants who could not afford counsel should be done by the public defenders of the Department of Labor as provided in Section 54 of Republic Act No. 1199; second, that Circular No. 5, dated June 28, 1957, of the Agricultural Tenancy Commission, as approved by the Secretary of Justice, creating a Tenancy Counsel Unit in the Mediation Division, was ultra vires and had no legal force; and third, that the Mediation Division of the Agricultural Tenancy Commission had been in existence without the sanction of any statute. An urgent motion for reconsideration was filed on September 29, 1958, but was denied on October 1, 1958.

Cordero then filed the present petition for certiorari and mandamus before the Supreme Court, seeking to nullify the September 22 and October 1, 1958 orders and to compel the respondent judge to allow trial attorneys of the Mediation Division to appear as counsel for indigent tenants. The Supreme Court issued a writ of preliminary injunction on August 21, 1958, restraining the respondent judge from enforcing his order. Meanwhile, Congress enacted Republic Act No. 2263, amending the Agricultural Tenancy Act, with Section 20 thereof amending Section 54 of Republic Act No. 1199 to provide that it shall be the duty of the trial attorney of the tenancy mediation commission to represent tenants who cannot afford counsel. After this enactment, petitioner filed a manifestation on August 11, 1959, arguing the issue had become moot and academic. The respondent judge filed a comment on October 3, 1959, contending that Sections 19 and 20 of Republic Act No. 2263 were null and void for violating the constitutional one-subject-one-title rule, since the creation of the Tenancy Mediation Division was not mentioned in the titles of either Republic Act No. 1199 or Republic Act No. 2263.

• Mootness: Petitioner contended, after the enactment of Republic Act No. 2263, that the issue had become moot and academic, the amendatory law having expressly authorized trial attorneys of the tenancy mediation commission to represent indigent tenants.
• Authority to Represent Indigent Tenants: Petitioner sought to compel the respondent judge to allow him and all trial attorneys of the Mediation Division of the Department of Justice to appear as counsel for indigent tenants in cases pending before the Court of Agrarian Relations, asserting the validity of their office and function.

• Unconstitutionality of Sections 19 and 20 of Republic Act No. 2263: Respondent judge argued that before the enactment of Republic Act No. 2263, there was no Tenancy Mediation Division in existence nor any law creating it or defining its functions, and that Sections 19 and 20 of Republic Act No. 2263 were null and void because they violated the constitutional requirement that no bill shall embrace more than one subject expressed in its title, the creation of the Tenancy Mediation Division not being mentioned in the titles of either Republic Act No. 1199 or Republic Act No. 2263.
• Proper Representation by Department of Labor: Respondent maintained that representation of indigent tenants belonged to the public defenders of the Department of Labor as provided in Section 54 of Republic Act No. 1199.
• Ultra Vires Creation of Tenancy Counsel Unit: Respondent asserted that Circular No. 5 of the Agricultural Tenancy Commission creating the Tenancy Counsel Unit was ultra vires and without legal force, and that the Mediation Division itself had existed without statutory sanction.

• Constitutionality of Sections 19 and 20 of Republic Act No. 2263: Whether Sections 19 and 20 of Republic Act No. 2263, which authorized the Secretary of Justice acting through a tenancy mediation division to carry out a national enforcement program including mediation of tenancy disputes and transferred the function of representing indigent tenants to the Department of Justice, violate the constitutional requirement under Article VI, Section 21, paragraph 1 of the Philippine Constitution that no bill shall embrace more than one subject which shall be expressed in the title of the bill.

• Constitutionality of Sections 19 and 20 of Republic Act No. 2263: Yes. The provisions are constitutional, the constitutional one-subject-one-title requirement being satisfied where all parts of the law are germane to the single general subject of agricultural tenancy expressed in the title of the amendatory act.

• Constitutionality of Sections 19 and 20 of Republic Act No. 2263: The constitutional requirement that the subject of an act be expressed in its title should receive a reasonable, not technical, construction. It is sufficient if the title is comprehensive enough reasonably to include the general object the statute seeks to effect, without expressing each and every end and means necessary or convenient for accomplishing that object. The title of Republic Act No. 2263 reads "AN ACT AMENDING CERTAIN SECTIONS OF REPUBLIC ACT NUMBERED ONE THOUSAND ONE HUNDRED NINETY-NINE, OTHERWISE KNOWN AS THE AGRICULTURAL TENANCY ACT OF THE PHILIPPINE," and the basic law, Republic Act No. 1199, is called "The Agricultural Tenancy Act of the Philippines." The constitutional requirement is complied with as long as the law has a single general subject — here, agricultural tenancy — and the amendatory provisions, no matter how diverse, are not inconsistent with or foreign to that general subject. The provisions of Sections 19 and 20 of Republic Act No. 2263 are germane to and reasonably necessary for the accomplishment of the one general subject of agricultural tenancy. Moreover, the only substantive change brought about by Republic Act No. 2263 was the transfer of the function of representing indigent tenants from the Department of Labor to the Department of Justice, apparently to consolidate enforcement of tenancy laws in the latter department; in essence, there was no fundamental change in the set-up established by Republic Act No. 1199, only a transfer of functions from one department to another. The Department of Labor had in fact issued a Memorandum Circular dated July 15, 1959, directing all its legal personnel to desist from performing legal aid functions in tenancy cases and to refer such cases to the Commissioner of the Tenancy Mediation Commission. To declare Sections 19 and 20 null and void would upset this transfer and frustrate Congress's intention to consolidate enforcement of tenancy laws in the Department of Justice.

• One Subject, One Title Rule — The constitutional requirement (Article VI, Section 21, paragraph 1, Philippine Constitution) that no bill enacted into law shall embrace more than one subject which shall be expressed in the title of the bill is satisfied if all parts of the law are related and germane to the subject matter expressed in the title. The requirement should receive a reasonable, not technical, construction; it is sufficient if the title is comprehensive enough reasonably to include the general object the statute seeks to effect, without expressing each and every end and means necessary or convenient for accomplishing that object. Mere details need not be set forth, and the title need not be an abstract or index of the Act. Where the law has a single general subject and the amendatory provisions, no matter how diverse, are not inconsistent with or foreign to that general subject, the provisions are valid. The Court applied this doctrine to hold that Sections 19 and 20 of Republic Act No. 2263, though creating a Tenancy Mediation Division and transferring functions, were germane to the general subject of agricultural tenancy expressed in the title of the amendatory law.

• "The constitutional requirement in question is satisfied if all parts of the law are related, and are germane to subject matter expressed in the title of the bill." — This passage states the controlling test for compliance with the one-subject-one-title rule, forming the ratio decidendi of the decision.

• "Constitutional provisions relating to the subject matter and titles of statutes should not be so narrowly construed as to cripple or impede the power of legislation. The requirement that the subject of an act shall be expressed in its title should receive a reasonable and not a technical construction." — This quotation, drawn from Government vs. Hongkong & Shanghai Banking Corporation, articulates the canonical formulation of the reasonable-construction principle for the one-subject-one-title rule, frequently cited in subsequent jurisprudence.

• "The constitutional rule is satisfied if all parts of a law relate to the subject expressed in its title." — This concise restatement, drawn from People vs. Carlos, captures the essence of the doctrine in a formulation commonly quoted in later cases.

• Government vs. Hongkong & Shanghai Banking Corporation, 66 Phil. 483 — Controlling precedent on the reasonable construction of the one-subject-one-title rule. The Court quoted its syllabus to support the principle that the constitutional requirement should not be so narrowly construed as to cripple legislative power and that the title need not be an index of the Act's contents.
• Sumulong vs. Commission on Elections, 73 Phil. 288 — Followed precedent establishing that the one-subject-one-title requirement is satisfied if the title expresses the general subject and all provisions are germane to that subject. The Court quoted its syllabus to reinforce the reasonable-construction approach.
• People vs. Carlos, 78 Phil. 535 — Followed precedent holding that the multitude of matters a statute must embrace need not all be mentioned in the title, and that the constitutional rule is satisfied if all parts relate to the subject expressed in the title. The Court quoted its syllabus for this proposition.
• Government of the Philippine Islands vs. Municipality of Binalonan, 32 Phil. 634 — Cited within People vs. Carlos for the principle that Congress is not expected to make the title of an enactment a complete index of its contents.

• Article VI, Section 21, paragraph 1, Philippine Constitution — The one-subject-one-title provision requiring 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." The Court applied this provision to test the validity of Sections 19 and 20 of Republic Act No. 2263 and found the requirement satisfied.
• Section 54, Republic Act No. 1199 (Agricultural Tenancy Act of the Philippines), as amended by Section 20, Republic Act No. 2263 — Provides that in all cases where a tenant cannot afford counsel, it shall be the duty of the trial attorney of the tenancy mediation commission to represent him, upon proper notification, or the court of competent jurisdiction shall assign counsel de oficio. This provision was the subject of the constitutional challenge and was upheld.
• Sections 19 and 20, Republic Act No. 2263 — Section 19 authorized the Secretary of Justice, acting through a tenancy mediation division, to carry out a national enforcement program including mediation of tenancy disputes. Section 20 amended Section 54 of Republic Act No. 1199 to transfer the function of representing indigent tenants to the trial attorneys of the tenancy mediation commission. Both sections were declared valid and constitutional.

Bengzon, C.J., Bautista Angelo, Labrador, Concepcion, Reyes, J.B.L., Barrera, Paredes, Dizon, and Makalintal concurred. Padilla, J., took no part.