ARTICLE VI - LEGISLATIVE DEPARTMENT

SECTION 26
SANTIAGO ALALAYAN VS NATIONAL POWER CORPORATION
24 SCRA 172 – Political Law – Title Must Express One Subject
FACTS: In 1961, Republic Act No. 3043 (An Act to Further Amend Commonwealth
Act Numbered One Hundred Twenty, as Amended by Republic Act Numbered
Twenty Six Hundred and Forty One) was passed. This law amended the charter
of NAPOCOR (National Power Corporation). Section 3 of RA 3043 provides that:
a. contractors being supplied by NAPOCOR shall not exceed an annual
profit of 12%;
b. if they do, they shall refund such excess to their customers;
c. that NAPOCOR has the power to renew all existing contracts with
franchise holders for the supply of energy.
Santiago Alalayan and the Philippine Power and Development Company
(PPDC) assailed the said provision.They averred that Section 3 is a rider because
first, it was not included in the title of the amending law nor was it included in
the amended law. Second, the main purpose of RA 3043 was to increase the
capital stock of NAPOCOR hence Alalayan et al believed that Section 3 was not
germane to RA 3043.
ISSUE: Whether or not Section 3 of RA 3043 is constitutional.
HELD: Yes. The Supreme Court simply ruled that the Constitution does not
require Congress to employ in the title of an enactment, language of such
precision as to mirror, fully index or catalogue all the contents and the minute
details therein. It suffices if the title should serve the purpose of the
constitutional demand that it inform the legislators, the persons interested in
the subject of the bill, and the public, of the nature, scope and consequences of
the proposed law and its operation. And this, to lead them to inquire into the
body of the bill, study and discuss the same, take appropriate action thereon,
and, thus, prevent surprise or fraud upon the legislators.