Cordero v. Cabatuando
REITERATIONFacts
The Antecedents: Petitioners Manuel A. Cordero and Vicente Salazar sought certiorari and mandamus to nullify an order of the Court of Agrarian Relations (CAR) disqualifying Cordero, a Trial Attorney of the Tenancy Unit, Mediation Division, Department of Justice, from appearing as counsel for indigent tenants. Cordero had filed a case for reinstatement and reliquidation of past harvests on behalf of tenant Vicente Salazar against landlord Leonardo Sta. Romana. Procedural History: Respondent landlord filed a motion to disqualify Cordero. On September 22, 1958, the CAR issued an order disqualifying Cordero and any other attorney from the Mediation Division from appearing for indigent tenants. A motion for reconsideration was denied on October 1, 1958. The CAR held that representation for indigent tenants should be by the public defender of the Department of Labor, that the creation of the Tenancy Unit Counsel was ultra vires, and that the Mediation Division existed without statutory sanction. The Petition: Petitioners filed the present petition for certiorari and mandamus to nullify the CAR's orders and compel the respondent judge to allow trial attorneys of the Mediation Division to appear for indigent tenants.
Issue(s)
Whether sections 19 and 20 of Republic Act No. 2263, amending Republic Act No. 1199, are constitutional. Whether the creation and functions of the Tenancy Mediation Division of the Department of Justice are valid.
Ruling
The petition is granted, and the writ of preliminary injunction is made permanent. The Court declared sections 19 and 20 of Republic Act No. 2263 valid and constitutional.
Ratio Decidendi
On the constitutionality of sections 19 and 20 of Republic Act No. 2263: The Court held that the constitutional requirement that no bill shall embrace more than one subject which shall be expressed in its title is satisfied if all parts of the law are related and germane to the subject expressed in the title. Republic Act No. 2263, titled "AN ACT AMENDING CERTAIN SECTIONS OF REPUBLIC ACT NUMBERED ONE THOUSAND ONE HUNDRED NINETY-NINE, OTHERWISE KNOWN AS THE AGRICULTURAL TENANCY ACT OF THE PHILIPPINE," has a single general subject, the Agricultural Tenancy Act. The amendatory provisions, including the transfer of the duty to represent indigent tenants to the Department of Justice, are germane to and reasonably necessary for the accomplishment of this general subject. The Court cited established jurisprudence that constitutional provisions on the subject matter and titles of statutes should be reasonably construed to avoid impeding legislation, and that mere details need not be set forth in the title. On the validity of the Tenancy Mediation Division: The Court found that the provisions of sections 19 and 20 of Republic Act No. 2263 are germane to the general subject of agricultural tenancy. The amendment essentially transferred the function of representing indigent tenants from the Department of Labor to the Department of Justice, consolidating tenancy law enforcement functions within the latter. This transfer was further supported by a Memorandum Circular from the Department of Labor, dated July 15, 1959, directing its legal personnel to desist from handling tenancy cases and to refer them to the Commissioner of the Tenancy Mediation Commission. Declaring these provisions void would upset this legislative intent to consolidate functions in the Department of Justice.
Main Doctrine
Sections 19 and 20 of Republic Act No. 2263, amending sections 53 and 54 of Republic Act No. 1199, are constitutional as the amendatory provisions are germane to the general subject of agricultural tenancy expressed in the title of the amendatory act, and the transfer of functions to the Department of Justice is a valid exercise of legislative power.