Tuesday, December 10, 2013

G.R. No. 105371 Case Digest

G.R. No. 105371 November 11, 1993
The Philippine Judges Association, etc., petitioners
vs Hon. Pete Prado, etc., respondents
Ponente: Cruz

Facts:
The petitioners are members of the mower courts who feel that their official functions as judges will be prejudiced by the Section 35 of RA No. 7354 through Circular No. 92-98 withdrawing the franking privilege from the SC, CA, RTC, MTCs and Land Registration of Deeds and other government offices.

Petitioners assails the constitutionality of RA No. 7354 on the grounds: (1) its title embraces more than one subject and does not express its purposes; (2) it did not pass the required readings in both Houses of Congress and printed copies of the bill in its final form were not distributed among the members before its passage; and (3) it is discriminatory and encroaches on the independence of the Judiciary.


Issue: the independence of the Judiciary.

Held:
(1) We are convinced that the withdrawal of the franking privilege from some agencies is germane to the accomplishment of the principal objective of R.A. No. 7354, which is the creation of a more efficient and effective postal service system. Our ruling is that, by virtue of its nature as a repealing clause, Section 35 did not have to be expressly included in the title of the said law.

(2) Applying these principles, we shall decline to look into the petitioners' charges that an amendment was made upon the last reading of the bill that eventually became R.A. No. 7354 and that copies thereof in its final form were not distributed among the members of each House. Both the enrolled bill and the legislative journals certify that the measure was duly enacted i.e., in accordance with Article VI, Sec. 26(2) of the Constitution. We are bound by such official assurances from a coordinate department of the government, to which we owe, at the very least, a becoming courtesy.

(3) The respondents counter that there is no discrimination because the law is based on a valid classification in accordance with the equal protection clause. In fact, the franking privilege has been withdrawn not only from the Judiciary but also the Office of Adult Education, the Institute of National Language; the Telecommunications Office; etc.

(4) We are unable to agree with the respondents that Section 35 of R.A. No. 7354 represents a valid exercise of discretion by the Legislature under the police power. On the contrary, we find its repealing clause to be a discriminatory provision that denies the Judiciary the equal protection of the laws guaranteed for all persons or things similarly situated. The distinction made by the law is superficial. It is not based on substantial distinctions that make real differences between the Judiciary and the grantees of the franking privilege.


It is unconstitutional.

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