Valentino Tio filed a petition challenging the constitutionality of Presidential Decree 1987, which created the Videogram Regulatory Board and imposed annual taxes of 5% and 30% on gross receipts for videogram operators. Tio argued the tax imposition violated the One-Subject-One-Title rule as the title only referred to creating the regulatory board and not imposing taxes. The Supreme Court held that the tax provision was not inconsistent with the title and general subject of regulating and rationalizing the videogram industry, as taxation was a direct consequence and regulatory mechanism to achieve the decree's purpose. Therefore, the tax imposition did not violate the One-Subject-One-Title rule.
Valentino Tio filed a petition challenging the constitutionality of Presidential Decree 1987, which created the Videogram Regulatory Board and imposed annual taxes of 5% and 30% on gross receipts for videogram operators. Tio argued the tax imposition violated the One-Subject-One-Title rule as the title only referred to creating the regulatory board and not imposing taxes. The Supreme Court held that the tax provision was not inconsistent with the title and general subject of regulating and rationalizing the videogram industry, as taxation was a direct consequence and regulatory mechanism to achieve the decree's purpose. Therefore, the tax imposition did not violate the One-Subject-One-Title rule.
Valentino Tio filed a petition challenging the constitutionality of Presidential Decree 1987, which created the Videogram Regulatory Board and imposed annual taxes of 5% and 30% on gross receipts for videogram operators. Tio argued the tax imposition violated the One-Subject-One-Title rule as the title only referred to creating the regulatory board and not imposing taxes. The Supreme Court held that the tax provision was not inconsistent with the title and general subject of regulating and rationalizing the videogram industry, as taxation was a direct consequence and regulatory mechanism to achieve the decree's purpose. Therefore, the tax imposition did not violate the One-Subject-One-Title rule.
Valentino Tio filed a petition challenging the constitutionality of Presidential Decree 1987, which created the Videogram Regulatory Board and imposed annual taxes of 5% and 30% on gross receipts for videogram operators. Tio argued the tax imposition violated the One-Subject-One-Title rule as the title only referred to creating the regulatory board and not imposing taxes. The Supreme Court held that the tax provision was not inconsistent with the title and general subject of regulating and rationalizing the videogram industry, as taxation was a direct consequence and regulatory mechanism to achieve the decree's purpose. Therefore, the tax imposition did not violate the One-Subject-One-Title rule.
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TITLE: VALENTIN TIO doing business under the name and style of OMI ENTERPRISES, petitioner, vs.
VIDEOGRAM REGULATORY BOARD, MINISTER OF FINANCE, METRO MANILA COMMISSION,
CITY MAYOR and CITY TREASURER OF MANILA, respondents. G.R. NO. L-75697 DATE: June 18, 1987 PONENTE: MELENCIO-HERRERA, J TOPIC: Sec. 26 - Requirements as to title of bills FACTS OF THE CASE: On September 1, 1986, Valentino Tio (Tio for brevity), on his own behalf and purportedly on behalf of other videogram operators adversely affected filed a petition assailing the constitutionality of Presidential Decree (P.D.) No. 1987 entitled “An Act Creating the Videogram Regulatory Board” with broad powers to regulate and supervise the videogram industry. Following its promulgation is the annual tax of 5% and 30% on gross receipts payable to the local government. The petitioner’s grounds is that the imposition of tax is a rider and is harsh and confiscatory, oppressive and/or unlawful restraint of trade. It is also alleged that the imposition of taxes is invalid since the title of the bill said only for the creation of the Videogram Regulatory Board, not for the imposition of taxes. This violates the One- Subject-One-Title Rule PROCEDURAL HISTORY: The case is a petition filed by petitioner on behalf of videogram operators adversely affected by Presidential Decree No. 1987 STATEMENT OF ISSUE/S: Whether or not the imposition of taxes is invalid in the promulgation of PD No. 1987. HOLDING No. The constitutional requirement that “Every Bill shall be expressed in the title thereof” is sufficiently complied with if the title is comprehensive enough to include the general purpose which statute seeks to achieve. It is not necessary that the title express each and every end that the stature wishes to accomplish. The requirement is satisfied if all the parts of the statutes are related and germane to the subject matter expressed in the title , or as long as they are not inconsistent with or foreign with the general subject and title. In the case at hand, the title may be read as only for the creation of the VRB, but the imposition of taxes is a direct consequence of the act, to perform its purpose to regulate and rationalize the heretofore uncontrolled distribution of videograms. 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 decree. notes, if any: