1-B, College of Law, San Beda Manila, A.Y.

2017-2018

Case Digest: GR No. 16197. March 12 1920

Central Capiz v. Ramirez
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 to do so upon the fact that
more than 61 percent 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.

Issue:
WON Act no. 2874 of Philippine Legislature applicable to agricultural lands held in private
ownership.
WON 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:
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 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.

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 graud
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, through such publication of legislative proceedings as is usually made,
of the subjects of legislation that are being considered, in order that they may have the
opportunity of being heard thereon by petition or otherwise if they shall so desire.
1. STATUTES, TITLE OF, MUST CONTAIN WHAT; PHRASE AND FOR OTHER PURPOSES"
IN TITLE OF STATUTE, EFFECT OF; PUBLIC LAND, DEFINED; ACT No. 2874, APPLICATION OF,
INTERPRETED. — Held: under the facts stated in the opinion —
 1-B, College of Law, San Beda Manila, A.Y. 2017-2018

(a) That it was the purpose and intent of the Legislature to comply with the
provisions of the Jones Law and to limit the application of Act No. 2874 to lands of the
public domain.
(b) That the phrase "and for other purposes," found in the title of said Act (No.
2874), by virtue of the provisions of section 3 of the Act of Congress of August 29, 1916 (the
Jones Law), cannot be interpreted to include, nor be made applicable to, any lands not
public.
(c) That eliminating the phrase "and for other purposes" from the title of said Act,
the same must be considered and treated as though reading: "An Act to amend and compile
the laws relative to lands of the public domain."
(d) That lands held in freehold or fee title, or private ownership, constitute no part
of the public domain and cannot possibly come within the purview of said Act No. 2874,
inasmuch as the "subject" of such freehold or private land, is not embraced in any manner
in the title of the Act.
||| (Capiz v. Ramirez, G.R. No. 16197, [March 12, 1920], 40 PHIL 883-902)