This document discusses several court cases related to legislative procedures and requirements under the Philippine constitution. It provides an overview of two methods for proving legislative proceedings: through journals or certified copies. It also discusses guidelines for determining if a bill's title conforms with the constitutional requirement that it only address a single subject. Finally, it outlines provisions in the constitution requiring each house to keep a journal of proceedings and bills to be printed and available for three days before passage.
This document discusses several court cases related to legislative procedures and requirements under the Philippine constitution. It provides an overview of two methods for proving legislative proceedings: through journals or certified copies. It also discusses guidelines for determining if a bill's title conforms with the constitutional requirement that it only address a single subject. Finally, it outlines provisions in the constitution requiring each house to keep a journal of proceedings and bills to be printed and available for three days before passage.
This document discusses several court cases related to legislative procedures and requirements under the Philippine constitution. It provides an overview of two methods for proving legislative proceedings: through journals or certified copies. It also discusses guidelines for determining if a bill's title conforms with the constitutional requirement that it only address a single subject. Finally, it outlines provisions in the constitution requiring each house to keep a journal of proceedings and bills to be printed and available for three days before passage.
This document discusses several court cases related to legislative procedures and requirements under the Philippine constitution. It provides an overview of two methods for proving legislative proceedings: through journals or certified copies. It also discusses guidelines for determining if a bill's title conforms with the constitutional requirement that it only address a single subject. Finally, it outlines provisions in the constitution requiring each house to keep a journal of proceedings and bills to be printed and available for three days before passage.
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Title of the Bill It will be seen upon examination of section 313 of the
Code of Civil Procedure, as amended by Act No. 2210,
Bara Lidasan V COMELEC that, roughly, it provides two methods of proving Petitioner relies upon the constitutional requirement legislative proceedings: (1) by the journals, or by aforestated, that "[n]o bill which may be enacted into published statutes or resolutions, or by copies certified law shall embrace more than one subject which shall be by the clerk or secretary or printed by their order; and expressed in the title of the bill." (2) in case of acts of the Legislature, by a copy signed by the presiding officers and secretaries thereof, which It may be well to state, right at the outset, that the shall be conclusive proof of the provisions of such Acts constitutional provision contains dual limitations upon and of the due enactment thereof. legislative power. First. Congress is to refrain from conglomeration, under one statute, of heterogeneous Journal Entry Rule subjects. Second. The title of the bill is to be couched in Astorga V Villegas a language sufficient to notify the legislators and the public and those concerned of the import of the single It may be noted that the enrolled bill theory is based subject thereof. mainly on "the respect due to coequal and independent departments," which requires the judicial department In our task of ascertaining whether or not the title of a "to accept, as having passed Congress, all bills statute conforms with the constitutional requirement, authenticated in the manner stated." Thus it has also the following, we believe, may be taken as guidelines: been stated in other cases that if the attestation is The test of the sufficiency of a title is whether or not it is absent and the same is not required for the validity of a misleading; and, which technical accuracy is not statute, the courts may resort to the journals and other essential, and the subject need not be stated in express records of Congress for proof of its due enactment. terms where it is clearly inferable from the details set But the said Constitution does contain the following forth, a title which is so uncertain that the average provisions: person reading it would not be informed of the purpose of the enactment or put on inquiry as to its contents, or Sec. 10 (4). "Each House shall keep a Journal of its which is misleading, either in referring to or indicating proceedings, and from time to time publish the same, one subject where another or different one is really excepting such parts as may in its judgment require embraced in the act, or in omitting any expression or secrecy; and the yeas and nays on any question shall, at indication of the real subject or scope of the act, is bad. the request of one-fifth of the Members present, be entered in the Journal." In determining sufficiency of particular title its substance rather than its form should be considered, and the Sec. 21 (2). "No bill shall be passed by either House purpose of the constitutional requirement, of giving unless it shall have been printed and copies thereof in its notice to all persons interested, should be kept in mind final form furnished its Members at least three calendar by the court. days prior to its passage, except when the President shall have certified to the necessity of its immediate Giron V COMELEC enactment. Upon the last reading of a bill no The proscription under Section 26(1), Article VI of the amendment thereof shall be allowed, and the question Constitution is aimed against the evils of the so-called upon its passage shall be taken immediately thereafter, omnibus bills and log-rolling legislation as well as and the yeas and nays entered on the Journal." surreptitious and/or unconsidered encroaches. The provision merely calls for all parts of an act relating to its subject finding expression in its title.