G.R. No. L-14542; October 31, 1962
MANUEL A. CORDERO, Trial Attorney of the Tenancy Unit, Mediation Division, Agricultural Tenancy Commission Department of Justice and VICENTE SALAZAR, petitioners, vs. HON. JOSE R. CABATUANDO, Associate Judge of the Court of Agrarian Relations, and LEONARDO STA. ROMANA, respondents.

FACTS

Petitioner Manuel A. Cordero, a Trial Attorney of the Tenancy Counsel Unit within the Mediation Division of the Agricultural Tenancy Commission under the Department of Justice, filed a tenancy case on behalf of indigent tenant Vicente Salazar before the Court of Agrarian Relations. Respondent landlord Leonardo Sta. Romana moved to disqualify Cordero, arguing that representation for indigent tenants should be handled by the public defenders of the Department of Labor as per the original text of the Agricultural Tenancy Act ( Republic Act No. 1199 ). The respondent Judge granted the motion, issuing an order disqualifying Cordero and any attorney from the Mediation Division, declaring the Commission’s circular creating the Tenancy Unit Counsel as ultra vires and noting the Division’s lack of statutory basis.
While the petition for certiorari and mandamus was pending before the Supreme Court, Congress enacted Republic Act No. 2263 , which amended the Agricultural Tenancy Act. Section 20 of this amendatory law specifically provided that it shall be the duty of the trial attorney of the tenancy mediation commission to represent indigent tenants. Petitioners thus filed a manifestation arguing the issue had become moot. Respondents countered, asserting that Sections 19 and 20 of Republic Act No. 2263 were unconstitutional for violating the constitutional requirement that no bill shall embrace more than one subject, which must be expressed in its title.

ISSUE

Whether Sections 19 and 20 of Republic Act No. 2263 , which created the Tenancy Mediation Division and assigned its trial attorneys the duty to represent indigent tenants, are unconstitutional for allegedly violating the “one title-one subject” rule of the Constitution.

RULING

The Supreme Court ruled that Sections 19 and 20 of Republic Act No. 2263 are constitutional and valid. The constitutional requirement is satisfied if all parts of the law are related and germane to the subject matter expressed in the title. The title of Republic Act No. 2263 is “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.” The creation of the Tenancy Mediation Division and the assignment of legal representation duties to its attorneys are amendments directly related to the general subject of agricultural tenancy. They are subordinate to the law’s objective of enforcing tenancy laws and protecting tenant rights. The Court emphasized that the title need not be an exhaustive index of every detail; it is sufficient that the provisions are not inconsistent with or foreign to the general subject. The amendment essentially consolidated the function of representing indigent tenants under the Department of Justice, a logical and germane adjustment within the framework of the Agricultural Tenancy Act. Therefore, the respondent Judge’s order of disqualification was nullified, and the writ of preliminary injunction was made permanent.