HELD: No.

1. The Constitutional requirement that “every bill shall embrace only one subject
Valentin Tio vs Videogram Regulatory Board
151 SCRA 208
Facts:
In 1985, Presidential Decree 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:
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.
2. There is no undue delegation of legislative powers to the VRB. VRB is not
being tasked to legislate. What was conferred to the VRB was the authority or
discretion to seek assistance in the execution, enforcement, and implementation of
the law. Besides, in the very language of the decree, the authority of the BOARD
to solicit such assistance is for a “fixed and limited period” with the deputized
agencies concerned being “subject to the direction and control of the VRB".

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 Tio’s arguments are correct.