G.R. No. 105371 November 11, 1993
THE PHILIPPINE JUDGES ASSOCIATION, duly represented by its President, BERNARDO P. ABESAMIS, Vice-President for Legal Affairs, MARIANO M. UMALI, Director for Pasig, Makati, and Pasay, Metro Manila, ALFREDO C. FLORES, and Chairman of the Committee on Legal Aid, JESUS G. BERSAMIRA, Presiding Judges of the Regional Trial Court, Branch 85, Quezon City and Branches 160, 167 and 166, Pasig, Metro Manila, respectively; the NATIONAL CONFEDERATION OF THE JUDGES ASSOCIATION OF THE PHILIPPINES, composed of the METROPOLITAN TRIAL COURT JUDGES ASSOCIATION represented by its President, REINATO QUILALA of the MUNICIPAL TRIAL CIRCUIT COURT, Manila; THE MUNICIPAL JUDGES LEAGUE OF THE PHILIPPINES represented by its President, TOMAS G. TALAVERA; by themselves and in behalf of all the Judges of the Regional Trial and Shari’a Courts, Metropolitan Trial Courts and Municipal Courts throughout the Country, petitioners,

vs.
HON. PETE PRADO, in his capacity as Secretary of the Department of Transportation and Communications, JORGE V. SARMIENTO, in his capacity as Postmaster General, and the PHILIPPINE POSTAL CORPORATION, respondents.

FACTS

Petitioners, various associations of judges from lower courts throughout the country, assail the constitutionality of Section 35 of Republic Act No. 7354 (the Act creating the Philippine Postal Corporation) and its implementing Circular No. 92-28. These measures withdrew the franking privilege from the Judiciary, including the Supreme Court, Court of Appeals, Regional Trial Courts, Metropolitan Trial Courts, Municipal Trial Courts, and the Land Registration Commission (later the National Land Registration Authority) and its Registers of Deeds. The petitioners argue that this withdrawal impairs the independence of the Judiciary. The National Land Registration Authority intervened, aligning with the petitioners. The petition challenges R.A. No. 7354 on three grounds: (1) its title embraces more than one subject and does not express its purposes, violating Article VI, Section 26(1) of the Constitution; (2) it did not pass the required readings in Congress, and printed copies in its final form were not distributed to members before passage, violating Article VI, Section 26(2); and (3) it is discriminatory and encroaches on judicial independence.

ISSUE

1. Whether Section 35 of R.A. No. 7354 violates the constitutional requirement that every bill shall embrace only one subject expressed in its title.
2. Whether the addition of the second paragraph of Section 35 (withdrawing the franking privilege) via a Conference Committee Report violated the constitutional procedure for passing bills.
3. Whether Section 35 of R.A. No. 7354 is discriminatory and violates the equal protection clause.

RULING

1. On the Title of the Law: The Court ruled that the title of R.A. No. 7354 , “An Act Creating the Philippine Postal Corporation, Defining its Powers, Functions and Responsibilities, Providing for Regulation of the Industry and for Other Purposes Connected Therewith,” does not violate the one-subject-one-title rule. The title fairly indicates the general subject and reasonably covers all provisions of the act. The withdrawal of the franking privilege via a repealing clause (Section 35) is germane to the act’s principal objective of creating an efficient postal system. A repealing clause is an effect, not the subject, of the law and need not be expressly mentioned in the title.
2. On the Legislative Procedure: The Court found no violation of constitutional procedure. The conference committee has broad functions and is not strictly limited to reconciling differences between houses; it may deal generally with the subject matter. The Conference Committee Report containing the challenged provision was duly approved by both the Senate and the House of Representatives, and the bill was properly enrolled. The enrolled bill doctrine presumes that the bill was passed in accordance with constitutional requirements.
3. On Discrimination and Equal Protection: The Court held that Section 35 violates the equal protection clause. The provision arbitrarily withdraws the franking privilege from the Judiciary and the Land Registration Authority while retaining it for other offices (specifically those under Commonwealth Act No. 265 , Republic Acts Nos. 69, 180, 1414, 2087, and 5059, the Vice President under certain conditions, and others under Circular No. 35). No substantial distinction justifies this differentiation. The franking privilege is essential for the Judiciary to perform its constitutional duties without dependence on the Executive branch, safeguarding its independence. The distinction is superficial and not based on real differences.
DISPOSITIVE PORTION:
The petition is partially GRANTED. The constitutionality of R.A. No. 7354 is sustained against the attacks on its title and the procedure of its passage. However, Section 35 of R.A. No. 7354 is declared UNCONSTITUTIONAL for violating the equal protection clause. Circular No. 92-28 is SET ASIDE insofar as it withdraws the franking privilege from the Supreme Court, the Court of Appeals, the Regional Trial Courts, the Municipal Trial Courts, and the National Land Registration Authority and its Registers of Deeds. The franking privilege is RESTORED to these offices. The temporary restraining order dated June 2, 1992, is made permanent.