151 SCRA 208 Political Law The Embrace of Only One Subject by a Bill

Delegation of Power Delegation to Administrative Bodies

In 1985, Presidential Dedree 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 Tios arguments are correct.

HELD: No.

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
be 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.