One Title, One Subject Rule – Oid Deregulation Law

Considering that oil is not endemic to this country, history shows that the government has
always been finding ways to alleviate the oil industry. The government created laws
accommodate these innovations in the oil industry. One such law is the Downstream Oil
Deregulation Act of 1996 or RA 8180. This law allows that "any person or entity may import or
purchase any quantity of crude oil and petroleum products from a foreign or domestic source,
lease or own and operate refineries and other downstream oil facilities and market such crude
oil or use the same for his own requirement," subject only to monitoring by the Department of
Energy. Tatad assails the constitutionality of the law. He claims that section 5 (b) of R.A. No. 8180
violates the one title one rule of Sec 26, Art 6 of the Constitution. Section 5 (b) provides:

"b) Any law to the contrary notwithstanding and starting with the effectivity of this Act, tariff
duty shall be imposed and collected on imported crude oil at the rate of three percent (3%) and
imported refined petroleum products at the rate of seven percent (7%), except fuel oil and LPG,
the rate for which shall be the same as that for imported crude oil: Provided, That beginning on
January 1, 2004 the tariff rate on imported crude oil and refined petroleum products shall be the
same: Provided, further, That this provision may be amended only by an Act of Congress."

The inclusion of the tariff provision in section 5(b) of R.A. No. 8180 violates Section 26(1) Article
VI of the Constitution requiring every law to have only one subject which shall be expressed in its
title. Petitioner contends that the imposition of tariff rates in section 5(b) of R.A. No. 8180 is
foreign to the subject of the law which is the deregulation of the downstream oil industry.

ISSUE: Whether or not RA 8180 is constitutional.

HELD: The SC declared the unconstitutionality of RA 8180 not because it violated the one title
one subject rule but rather because it violated Sec 19 of Art 12 of the Constitution. It violated
that provision because it only strengthens oligopoly which is contrary to free competition. The
SC emphasized that the provision of Sec 5 (b) of RA 8180 does not violate the one title one
subject rule. The SC, as a policy, has adopted a liberal construction of the one title - one subject
rule. The SC also emphasized that the title need not mirror, fully index or catalogue all contents
and minute details of a law. A law having a single general subject indicated in the title may
contain any number of provisions, no matter how diverse they may be, 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 general subject. The SC held
that section 5(b) providing for tariff differential is germane to the subject of RA 8180 which is the
deregulation of the downstream oil industry. The section is supposed to sway prospective
investors to put up refineries in our country and make them rely less on imported petroleum.