Case Digest (G.R. No. L-24396)
Facts:
The case involves Santiago P. Alalayan and the Philippine Power and Development Company as petitioners-appellants against the National Power Corporation (NPC) and the Administrator of Economic Coordination as respondents-appellees. The proceedings began in the lower court to challenge the validity of a provision in Republic Act No. 3043, which was enacted on June 17, 1961. This provision allowed the NPC to require franchise holders, who received at least 50% of their electric power from it, to limit their net profits to a maximum of twelve percent annually of their investments plus two months of operating expenses. The petitioners, both franchise holders of electric plants in Laguna, argued that this provision was unconstitutional as it violated the single subject rule and due process rights, particularly the liberty to contract. The lower court upheld the validity of the provision, leading to the appeal by Alalayan. The case was marked by a series of events, including the NP...
Case Digest (G.R. No. L-24396)
Facts:
Parties Involved:
- Petitioners: Santiago P. Alalayan and Philippine Power and Development Company (later dismissed from the case).
- Respondents: National Power Corporation (NPC) and the Administrator of Economic Coordination.
Nature of the Case:
- A declaratory relief proceeding was initiated by the petitioners to challenge the constitutionality of Section 3 of Republic Act No. 3043, which empowered the NPC to limit the net profits of franchise holders receiving at least 50% of their electric power from NPC to 12% annually of their investments plus two-month operating expenses.
Background of the Dispute:
- Petitioners were franchise holders of electric plants in Laguna and had existing contracts with NPC for the supply of electric power.
- On June 17, 1961, Republic Act No. 3043 was enacted, amending the charter of NPC and including the contested provision.
- NPC announced a rate increase of 17.5%, which petitioners opposed, arguing that the provision was unconstitutional.
Petitioners' Claims:
- The provision was a "rider" and violated the constitutional requirement that a bill must embrace only one subject, expressed in its title.
- The provision infringed on their liberty to contract and violated the due process clause.
- They sought a declaration of unconstitutionality and an injunction to prevent NPC from enforcing the provision.
Lower Court Decision:
- The lower court sustained the validity of the provision, prompting the petitioners to appeal.
Issue:
- Constitutionality of the Provision:
- Whether Section 3 of Republic Act No. 3043 violated the constitutional requirement that a bill must embrace only one subject, expressed in its title.
- Whether the provision infringed on the petitioners' liberty to contract and violated the due process clause.
- Whether the provision impaired the obligation of contracts, violating the constitutional prohibition against laws impairing the obligation of contracts.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)