Philippine Judges Association v. Prado G.R. No. 105371 November 11, 1993 Cruz, J.

FACTS: The Philippine Postal Corporation issued Circular No. 92-28 to implement Section 35 of RA No. 7354. The said provision withdraws 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. However, it has retained the franking privilege for the President and Vice President of the Philippines, Senator and members of the House of Representatives, COMELEC, National Census and Statistics Office, as well as former presidents of the Philippines and the general public. The petitioners, who are members of the lower courts, assail the constitutionality of the RA 7354 on 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. On the third ground, 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: WON RA 7354 is unconstitutional HELD: Yes. Regarding the title of the Act, The Supreme Court 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. The Court also dismissed the second ground for the Court may not inquire beyond the certification of the approval of a bill from the presiding officers of Congress. However, the Supreme Court declared that the ruling out of franking privileges to the Judiciary is violative of the equal protection clause. In lumping the Judiciary with the other offices from which the franking privilege has been withdrawn, Section 35 has placed the courts of justice in a category to which it does not belong. According to a long line of decisions, equal protection simply requires that all persons or things similarly situated should be treated alike, both as to rights conferred and responsibilities imposed. Similar subjects, in other words, should not be treated differently, so as to give undue favor to some and unjustly discriminate against others. If it recognizes the need of the President of the Philippines and the members of Congress for the franking privilege, there is no reason why it should not recognize a similar and in fact greater need on the part of the Judiciary for such privilege. Therefore, Section 35 of RA 7354 is declared UNCONSTITUTIONAL.

Tolentino v. Secretary of Finance G.R. No. 115525 August 25, 1994 Mendoza, J.

FACTS: RA 7716, known as the Expanded Value-Added Tax Law, is an act that seeks to widen the tax base of the existing VAT system and enhance its administration by amending the National Internal Revenue Code. However, many has questioned its constitutionality.Petitioners contend that the RA 7716 did not originate exclusively from the House of Representatives but is a mere consolidation of HB. No. 11197 and SB. No. 1630, thus violating Article VI, Sec. 24 of the Constitution. It was said that it also did not pass three readings on separate days on the Senate thus violating Article VI, Sections 24 and 26(2) of the Constitution, respectively. ISSUE: WON RA 7716 violates Article VI, Sections 24 and 24(2) of the Constitution HELD: No. To begin with, it is not the law but the revenue bill which is required by the Constitution to "originate exclusively" in the House of Representatives. It is important to emphasize this, because a bill originating in the House may undergo such extensive changes in the Senate that the result may be a rewriting of the whole. At this point, what is important to note is that, as a result of the Senate action, a distinct bill may be produced. To insist that a revenue statute and not only the bill which initiated the legislative process culminating in the enactment of the law must substantially be the same as the House bill would be to deny the Senate's power not only to "concur with amendments" but also to "propose amendments." It would be to violate the coequality of legislative power of the two houses of Congress and in fact make the House superior to the Senate. The argument that the bill did not pass three readings on separate days as required by the Constitution because the second and third readings were done on the same day, March 24, 1994 untenable. This was because on February 24, 1994 and again on March 22, 1994,the President had certified S. No. 1630 as urgent. The presidential certification dispensed with the requirement not only of printing but also that of reading the bill on separate days. The phrase "except when the President certifies to the necessity of its immediate enactment, etc." in Art. VI, Sec. 26(2) qualifies the two stated conditions before a bill can become a law: (i) the bill has passed three readings on separate days and (ii) it has been printed in its final form and distributed three days before it is finally approved. Therefore, RA 7716 is not unconstitutional.