PHIL JUDGES ASSOCIATION VS PRADO ENBANC

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227 SCRA 703 G.R. No. 105371 November 11, 1993

FACTS:
Petitioners assailed the validity of Sec 35 R.A. No. 7354 which 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.
The petition assails the constitutionality of R.A. No. 7354 on the grounds that: (1) its 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 RA 7354 is constitutional.

RULING:
No. SC held that Sec 35 R.A. No. 7354 is unconstitutional.

1. Article VI, Sec. 26(l), of the Constitution providing that "Every bill passed by the Congress shall
embrace only one subject which shall be expressed in the title thereof."
The title of the bill is not required to be an index to the body of the act, or to be as comprehensive as to
cover every single detail of the measure. It has been held that if the title fairly indicates the general
subject, and reasonably covers all the provisions of the act, and is not calculated to mislead the
legislature or the people, there is sufficient compliance with the constitutional requirement.
We are convinced that the withdrawal of the franking privilege from some agencies is germane to the
accomplishment of the principal objective of R.A. No. 7354, which is the creation of a more efficient and
effective postal service system. Our ruling is that, by virtue of its nature as a repealing clause, Section 35
did not have to be expressly included in the title of the said law.

2. The petitioners maintain that the second paragraph of Sec. 35 covering the repeal of the franking
privilege from the petitioners and this Court under E.O. 207, PD 1882 and PD 26 was not included in the
original version of Senate Bill No. 720 or House Bill No. 4200. As this paragraph appeared only in the
Conference Committee Report, its addition, violates Article VI, Sec. 26(2) of the Constitution. The
petitioners also invoke Sec. 74 of the Rules of the House of Representatives, requiring that amendment to
any bill when the House and the Senate shall have differences thereon may be settled by a conference
committee of both chambers.
Casco Philippine Chemical Co. v. Gimenez laid down the rule that the enrolled bill, is conclusive
upon the Judiciary (except in matters that have to be entered in the journals like the yeas and nays on the
final reading of the bill). The journals are themselves also binding on the Supreme Court.
Applying these principles, we shall decline to look into the petitioners' charges that an amendment was
made upon the last reading of the bill that eventually became R.A. No. 7354 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 i.e., in accordance with Article VI, Sec. 26(2)
of the Constitution. We are bound by such official assurances from a coordinate department of the
government, to which we owe, at the very least, a becoming courtesy.

3. SC annuls Section 35 of the law as violative of Article 3, Sec. 1, of the Constitution providing that no
person shall "be deprived of the equal protection of laws."
It is worth observing that the Philippine Postal Corporation, as a government-controlled corporation, was
created and is expected to operate for the purpose of promoting the public service. While it may have
been established primarily for private gain, it cannot excuse itself from performing certain functions for the
benefit of the public in exchange for the franchise extended to it by the government and the many
advantages it enjoys under its charter. 14 Among the services it should be prepared to extend is free
carriage of mail for certain offices of the government that need the franking privilege in the discharge of
their own public functions.
Categories: Constitutional Law 1

hilippine Judges Association vs. Prado

GR No. 105371, November 11, 1993 (227 SCRA 703) 

FACTS:

This is a petition raised by the members of the lower courts who assails the
constitutionality of Section 35 of Republic Act No. 7354 implemented by the
Philippine Postal Corporation through its Circular No. 92-28. Philippine Judges
Association vs. Prado

It is alleged that the said law is discriminatory per se to withdraw the franking
privilege of the Judiciary but not on other offices of the government, such as:  the
President of the Philippines, the Vice President of the Philippines; Senators and
Members of the House of Representatives; the Commission on Elections; former
Presidents of the Philippines; the National Census and Statistics Office; and the
general public in the filing of complaints against public offices and officers.

However, the respondents contend that there is no discrimination since the law is
based on the valid classification in accordance of the equal protection clause. In
addition, not only the Judiciary department will be affected with it but also other
offices like Office of Adult Education, the Institute of National Language; the
Telecommunications Office; the Philippine Deposit Insurance Corporation; the
National Historical Commission; etc. Philippi

Philippine Judges Association Vs. Prado Case Digest

Philippine Judges Association Vs. Prado 

227 SCRA 703

G.R. No. 105371

November 11, 1993

Facts: The Philippine Postal Corporation issued circular No. 92-28 to implement Section 35 of RA 7354
withdrawing the franking privilege from the SC, CA, RTCs, MeTCs, MTCs and Land Registration
Commission and with certain other government offices. It is alleged that RA 7354 is discriminatory
becasue while withdrawing the franking privilege from judiciary, it retains the same for the President &
Vice-President of the Philippines, Senator & members of the House of Representatives, COMELEC,
National Census & Statistics Office and the general public. The respondents counter that there is no
discrimination because the law is based on a valid classification in accordance with the equal protection
clause. 

Issue: Whether or Not Section 35 of RA 7354 is constitutional. 

Held: The equal protection of the laws is embraced in the concept of due process, as every unfair
discrimination offends the requirements of justice and fair play. It has nonetheless been embodied in a
separate clause in Article III Section 1 of the Constitution to provide for amore specific guarantee against
any form of undue favoritism or hostility from the government. Arbitrariness in general may be challenged
on the basis of the due process clause. But if the particular act assailed partakes of an unwarranted
partiality or prejudice, the sharper weapon to cut it down is the equal protection clause. Equal protection
simply requires that all persons or things similarly situated should be treated alike, both as to rights
conferred and responsibilities imposed. What the clause requires is equality among equals as determined
according to a valid classification. Section 35 of RA 7354 is declared unconstitutional. Circular No. 92-28
is set aside insofar
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ne Judges Association vs. Prado