Cited Laws
TL;DR — Ruling
WHEREFORE, foregoing premises considered, Sections [4(c)(1)] and 8 of RA [No.] 10635 and each counterpart provisions in its Implementing Rules and Regulation[s] are hereby declared valid and constitutional. The petition is hereby dismissed for lack of merit. IT IS SO CONSIDERED.
WHEREFORE, foregoing premises considered, Sections [4(c)(1)] and 8 of RA [No.] 10635 and each counterpart provisions in its Implementing Rules and Regulation[s] are hereby declared valid and constitutional. The petition is hereby dismissed for lack of merit. IT IS SO CONSIDERED. [5] Aggrieved, petitioners appealed directly to the Court on pure question of law and reiterated that Sections (4)(c)(1) and 8 are " rider provisions ." The petitioners claim that the transfer of regulatory powers is unnecessary and would result in outright deprivation of the professional status of thousands of marine deck and engine officers. [6] In contrast, the respondents, in their Comment, [7] maintained that the title of Republic Act No. 10635 shows that Congress, in establishing MARINA as the single maritime administration agency for the implementation of maritime international agreements, necessarily transferred to it all the powers and functions that used to be with other government agencies. The respondents added that the transfer of PRC's powers, duties, and functions to MARINA relative to the examination, licensing, and certification system of marine deck and engine officers is germane to the subject matter of Republic Act No. 10635, i.e., the establishment of MARINA as the single maritime administration charged with the responsibility of ensuring compliance with the STCW Convention. Lastly, the respondents averred that any question about the necessity of power transfer is not justiciable because it essentially refers into the wisdom of Congress. [8] RULING The Petition is unmeritorious. The " one subject-one title " rule is aimed against the evils of " omnibus bills " and " log-rolling legislation ," as well as surreptitious and/or unconsidered encroaches. [9] Case law instructs that the "constitutional requirement that the subject of an act shall be expressed in its title should be reasonably construed so as not to interfere unduly with the enactment of necessary legislation. It should be given a practical rather than technical construction": [10] Moreover, a liberal construction of the " one title-one subject " rule has been invariably adopted by this court so as not to cripple or impede legislation . Thus, in Sumulong v. Comelec , we ruled that the constitutional requirement as now expressed in Article VI, Section 26(1) "should be given a practical rather than a technical construction. It should be sufficient compliance with such requirement if the title expresses the general subject and all the provisions are germane to that general subject ." [11] (Emphasis supplied, citation omitted) In Tatad v. The Secretary of the Department of Energy , [12] this Court ruled that "a law having a single general subject indicated in the title may contain any number of provisions, . . . so long as they are not inconsistent with or foreign to the general subject, and may be considered in furtherance of such subject by providing for the method and means of carrying out the