ARTICLE VI - LEGISLATIVE DEPARTMENT

SECTION 26
MANUEL CORDERO VS JOSE CABATUANDO
6 SCRA 418 – Political Law – One Title, One Subject Rule – Tenancy Act
FACTS: Manuel Cordero was the trial lawyer of the Tenancy Counsel Unit
(TCU) of the Agricultural Tenancy Commission of the Department of Justice. He
later appeared as the counsel of indigent tenant Vicente Salazar who filed a
case against landlord Leonardo Sta. Romana in order to reinstate and
reliquidate past harvests. Sta. Romana filed a motion to disqualify Cordero as
counsel for Salazar and he invoked Sec. 54 of Republic Act No. 1199 or The
Agricultural Tenancy Act of the Philippines. The said section indicates that
representation by counsel of tenants who cannot afford to pay should be done
by the public defenders of the Department of Labor.
Judge Jose Cabatuando ruled in favor of Sta. Romana. Cordero
appealed. During pendency of the appeal Republic Act No. 2263, AN ACT
AMENDING CERTAIN SECTIONS OF REPUBLIC ACT NUMBERED ONE
THOUSAND ONE HUNDRED NINETY-NINE, OTHERWISE KNOWN AS THE
AGRICULTURAL TENANCY ACT OF THE PHILIPPINES, was passed. This law,
particularly Sections 19 and 20 thereof, amended the previous law and now
allows trial lawyers from the TCU to represent indigent tenants and it is also
the basis of the creation of the Tenancy Mediation Division. Cordero filed a
Manifestation averring that by virtue of the amendment the issue has now
become moot and academic. Cabatuando countered that the provisions were
not embraced in the title of the amending law nor in the amended law hence
void.

ISSUE: Whether or not the creation of the TMD is embraced in the title of the
bill and whether or not to allow trial lawyers from TCU to appear as counsel for
indigent tenants should be allowed.

HELD: Yes. The Supreme Court ruled that that the constitutional requirement
in question is satisfied if all parts of the law are related, and are germane to the
subject matter expressed in the title of the bill.The constitutional requirement
is complied with as long as the law, as in the instant case, has a single general
subject which is the Agricultural Tenancy Act and the amendatory provisions
no matter how diverse they may be, so long as they are not inconsistent with or
foreign to the general subject, will be regarded as valid. To declare sections 19
and 20 of RA 2263 null and void would in effect upset the transfer of the duty
of representing indigent tenants from the public defenders of the Department of
Labor to the trial attorneys in the Mediation Division of the Agricultural
Tenancy Commission of the Department of Justice. In other words, a
declaration of nullity of these provisions of RA 2263 would do harm to, and
would be nugatory of, the intention of Congress to consolidate the function of
enforcing our tenancy laws in the Department of Justice.