THE PHILIPPINE JUDGES ASSOCIATION vs. HON.

PETE PRADO

G.R. No. 105371 November 11, 1993

Material Facts:

Petitioners are judges represented by the Philippine Judges Association, questioning the validity of Republic
Act 7354 specifically Sec 35 of the said act with the title, "An Act Creating the Philippine Postal Corporation,
Defining its Powers, Functions and Responsibilities, Providing for Regulation of the Industry and for Other
Purposes Connected Therewith.". The measures indicated in the provision withdraw the franking privilege
from the Supreme Court, the Court of Appeals, the Regional Trial Courts, the Metropolitan Trial Courts, the
Municipal Trial Courts, and the Land Registration Commission and its Registers of Deeds, along with certain
other government offices. In their petition, they have identified the following as grounds: (1) the 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:

Whether or not Sec 35 of Republic Act 7354 is constitutional

Ruling:

No. SC held that Sec 35 of Republic Act. 7354 is unconstitutional.

The Supreme Court does not agree that the title of the challenged act violates the Constitution. The higher
court argued that Sec 35 did not have to be included in the title as it is germane to the accomplishment of the
objective of the act. If the title has indicated the general subject, covered the provisions, and does not lead the
legislature or the people, there is sufficient compliance with the constitutional requirement. As for the
petitioners second argument, the SC did not acknowledge their charges that an amendment was made upon
the last reading of the bill 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 in
accordance with Article VI, Sec. 26(2) of the Constitution. Lastly, SC disagrees with respondents that the
withdrawal of franking privilege is a valid exercise of discretion. SC Supports the petitioners contention that
the provision is discriminatory as it denies the Judiciary the equal protection of laws. The distinction is not
substantive as to warrant such withdrawal of the franking privilege from the Judiciary. In sum, SC partially
granted the petition while declared Sec 35 of the act as violative of the equal protection clause.