PHILCONSA VS. GIMENEZ

FACTS
RA No. 3836, “An Act Amending Subsection ©, Section 12 of Commonwealth Act Numbered 186. As Amended by Republic Act Numbered 3096”, allows a Senator or a member of the House of Representatives and an elective officer of either House of Congress to retire regardless of age and whose service must be at least 12 years. Philippine Constitution Association, Inc. , a non-profit civic organization duly incorporated under Philippine laws instituted  this petition challenging the constitutionality of the law in question.

ISSUE
Whether or not the little of RA No. 3836 is germane to the subject matter expressed in the act.

HELD
No. It is to be observed  that under RA No. 3836, amending the first paragraph of section 12, subsection c of CA No. 186, retirement benefits are granted to members of GSIS. This paragraph is related and germane to the subject of CA No. 186. The succeeding paragraph of RA. No 3836 refers to members of Congress and elective in any manner to the subject of CA. No. 186 establishing the GSIS and which provides both retirement and issuance benefits to its members.

            The constitutionality requirement with respect to titles of statutes as sufficient to reflect their contents is not met by the title of said RA. No. 3836, thus , void.

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