Case Digest (G.R. No. 105371)
Facts:
The Philippine Judges Association et al., G.R. No. 105371, November 11, 1993, the Supreme Court En Banc, Cruz, J., writing for the Court. The petitioners are associations and individual judges of the lower courts (Regional Trial Courts, Metropolitan Trial Courts, Municipal Courts) who challenged the withdrawal of the franking (official free-postage) privilege from the Judiciary under Section 35 of R.A. No. 7354 and its implementation by Philippine Postal Corporation Circular No. 92-28. The National Land Registration Authority (NLRA) intervened by leave, asserting that the withdrawal also affected its duties (sending notices in registration cases).Chronologically, Congress enacted R.A. No. 7354 (chartering the Philippine Postal Corporation) with a repealing clause in Section 35 that abolished “all franking privileges authorized by law” except certain enumerated exceptions and allowed limited continuance of some franking arrangements. The Corporation issued Circular No. 92-28 implementing the provision and withdrawing the Judiciary’s franking privilege. The petitioners sought judicial relief, asserting (1) the law’s title embraced more than one subject and failed to express its purposes (Art. VI, Sec. 26(1) Constitution); (2) the contested paragraph of Section 35 was added improperly via a Conference Committee without compliance with the three-readings rule and distribution requirement (Art. VI, Sec. 26(2)); and (3) Section 35 is discriminatory and violates the equal protection guaranty (Art. III, Sec. 1).
The NLRA was allowed to intervene. A temporary restraining order dated June 2, 1992 enjoined implementation of the withdrawal; the case was heard by the Court En Banc. The Supreme Court re...(Subscriber-Only)
Issues:
- Does Section 35 of R.A. No. 7354, as enacted, violate Article VI, Section 26(1) of the Constitution because its title does not express the subject of withdrawing franking privileges?
- Did inclusion of the paragraph in Section 35 in the enrolled bill via the Conference Committee violate Article VI, Section 26(2) (three readings and distribution of final printed copies), rendering the provision invalid?
- Does Section 35, insofar as it withdraws the franking privilege from the Judiciary and the NLRA and its Registers of Deeds, violate the equal protection ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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