VIII. Powers of Congress
No.
Case Title
Facts
Issue/s
Held
1
2
Gonzales v.
Hechanova
*RA 3452 (amended or repealed RA 2207) explicitly prohibits importation of
rice and corn by the Rice and Corn Administration or any other government
agency
*PH entered into contracts for the purchase of rice with Vietnam and Burma;
these are valid agreements under international law
*Whether the rice importation contracts are
vaild
*
NO.
Under the Constitution, the main function of the Executive is to enforce
laws enacted by Congress. The former may not interfere in the performance of
the legislative powers of the latter, except in the exercise of the veto power. He
may not defeat legislative enactments that have acquired the status of laws, by
indirectly repealing the same through an executive agreement providing for the
performance of the very act prohibited by said laws.
*Although the President may, under the American constitutional system, enter
into executive agreements without previous legislative authority, he may not, by
executive agreement, enter into a transaction which is prohibited by statutes
enacted prior thereto.
PHILCONSA v.
Gimenez
*Suit in instituted by the Philippine Constitution Assn (Philconsa), a non-
profit, civic org
*RA 3836 (AN ACT AMENDING SUBSECTION (c), SECTION TWELVE OF
COMMONWEALTH ACT No. 186 AS AMENDED BY REPUBLIC ACT No. 3096)
*Said Act provides for the retirement ben
ts for members of Congress which
e
e
in effect are increases in the emoluments of Senators and Members of the
House of Representatives, to take effect upon the approval of the Act, which
was on June 22, 1963. Retirement benefits were immediately available
thereunder without awaiting the expiration of the full term of all the
Members of the Senate and the House of Representatives approving such
increase.
Service Insurance System.
*Whether RA 3836 violated Sec. 26(1), Art. VI
of the Constitution - One subject, One title
rule
*YES. *Under the Act, the retirement benefits are granted to members of the
Government Service Insurance System who have rendered at least twenty years of
service regardless of age. This provision is related and germane to the subject of
Commonwealth Act 186. On the other hand, the succeeding paragraph of RA 3836
refers to members of Congress and to elective officers thereof who are not
members of the Government. To provide retirement benefits, therefore, for these
officials, would relate to subject matter, not germane to Commonwealth Act No.
186.
Lidasan v.
COMELEC
*The suit is instituted by Lidasan, a resident and taxpayer of Parang, Cotabato
*RA 4790 (An Act Creating the Municipality of Dianaton in the Province of
Lanao del Sur)
*Said RA included barrios located in the province of Cotabato
*Whether RA 4790 violated Sec. 26(1), Art. VI
of the Constitution - One subject, One title
rule
*
YES
. The constitutional provision contains dual limitations upon legislative
power. First. Congress is to refrain from conglomeration, under one statute, of
heterogeneous subjects. Second. The title of the bill is to be couched in a
