TIO Vs VIDEOGRAM

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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:

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