Central Capiz v.

Ramirez
G.R. No. 16197. March 12, 1920
FACTS:
The petitioner alleges and respondent admits that on or about July 1, 1919, the
latter contracted with the petitioner to supply to it for a term of thirty years all
sugar cane produced upon her plantation. Said contract was recorded in the
Registry of Property. In the interim the execution of said contract, Act No. 2874
of the Philippine Legislature, known as the "Public Land Act," became effective.
The respondent, while admitting said contract and her obligation thereunder to
execute a deed pursuant thereto, bases her refusal so to do upon the fact that
more than 61 per cent of the capital stock of the petitioner is held and owned by
persons who are not citizens of the Philippine Islands or of the United States.
ISSUES:
(1) Whether or not RA 2874 applies to agricultural lands held in private ownership.
(2) Whether or not complies with the constitutional requirement "That no bill which
may be enacted into law shall embrace more than one subject, and that subject
shall be expressed in the title of the bill."
HELD:
(1) No. It is held that Act No. 2874 was intended to apply to and regulate the sale,
lease and other disposition of public lands only. The title of the Act, always
indicative of legislative intent, reads: "an Act to amend and compile the laws
relating to lands of the public domain , and for other purposes. Said act, by
express provisions of Sections 4, 5, 67 and 105, does not apply to lands privately
owned by the government. The Act nowhere contains any direct
or express provision applying its terms to privately owned lands. The court holds,
therefore, that the purpose of the Legislature in adopting Act No. 2874 was and is
to limit its application to lands of the public domain, and that lands held in private
ownership are not included therein and are not affected in any manner whatsoever.
(2) No. The objects of the constitutional requirement under Section 3 of the Jones
Law are first, to prevent hodge-podge or log-rolling legislation;second, to prevent
surprise or fraud upon the legislature by means of provisions in bills of which the
titles gave no information, and which might therefore be overlooked and carelessly
and unintentionally adopted; and , third, to fairly apprise the people of the
subjects of legislation that are being considered, in order that they may have

opportunity of being heard thereon by petition or otherwise if they shall so

desire.' (Cooley's Constitutional Limitations, p. 143.) This constitutional
requirement is mandatory and not directory. In the said Act, the words "and for
other purposes" contained in its title, must be treated as non-existent, held to be
without force or effect whatsoever and have been altogether discarded in
construing the Act. That the use of the words "other purposes," can no longer be
of any avail as they express nothing and amount to nothing as a compliance with
this constitutional requirement. The phrase expresses no specific purpose and
imports indefinitely something different from that which precedes it in the title.