Case Digest (G.R. No. 222086)
Facts:
Hermogenes P. Pobre, Rudegelio D. Tacorda, United Filipino Seafarers, Inc., represented by its President, Nelson G. Ramirez, and Bienvenido S. Lorque v. Maritime Industry Authority (MARINA), represented by its Administrator, Hon. Maximo Q. Mejia, Jr., and Department of Transportation and Communication (DOTC), represented by its Secretary, Hon. Joseph Emilio A. Abaya, G.R. No. 222086, May 20, 2025, the Supreme Court En Banc, Lopez, M., J., writing for the Court.On March 28, 2014, Republic Act No. 10635 took effect, establishing MARINA as the single maritime administration responsible for implementing and enforcing the 1978 International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW Convention). Sections 4(c)(1) and 8 of RA 10635 expressly transferred to MARINA “all powers, duties and functions of the Professional Regulation Commission (PRC) on examination, licensing and certification system for marine deck and engine officers,” and provided transitional rules validating pre-existing certificates until expiration.
On November 27, 2014, petitioners — Hermogenes P. Pobre, Rudegelio D. Tacorda, Bienvenido S. Lorque, and United Filipino Seafarers, Inc. (represented by Nelson G. Ramirez) — filed a Special Civil Action for prohibition, mandamus, and declaratory relief (Special Civil Action No. R‑QZN‑14‑11759‑CV) before the Regional Trial Court (Branch 92, Quezon City), challenging Sections 4(c)(1) and 8 of RA 10635 as unconstitutional under Article VI, Section 26(1) of the 1987 Constitution (the one subject‑one title rule), alleging those provisions were riders not reflected in the statute’s title. The complaint was adjudicated by Presiding Judge Eleuterio L. Bathan.
On December 14, 2015, the RTC dismissed the Special Civil Action for lack of merit and declared Sections 4(c)(1) and 8 valid and constitutional, reasoning the provisions were germane to the law’s purpose of consolidating MARINA’s role to ensure compliance with the STCW Convention. Aggrieved, petitioners sought relief before the Supreme Court by a petition for review on certiorari under Rule 45, renewing attacks that the transfer of PRC powers to MARINA were unauthorized “riders,” that the transfer would deprive thousands of marine officers of their professional status, and that the transfer w...(Subscriber-Only)
Issues:
- Does Sections 4(c)(1) and 8 of Republic Act No. 10635 violate Article VI, Section 26(1) of the 1987 Constitution (the one subject–one title rule)?
- Is the petitioners’ contention that the transfer of regulatory powers from PRC to MARINA was unnecessary justiciable, or is it a political ques...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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