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Tio Vs Videogram

The case Tio vs. Videogram Regulatory Board challenges the constitutionality of PD 1987, which established the Videogram Regulatory Board with powers to regulate the videogram industry, including tax provisions. The ruling determined that PD 1987 is constitutional, as its title and provisions are comprehensive and aligned with its regulatory purpose. The tax provision is deemed necessary for the regulation and rationalization of the video industry, as outlined in the decree's preambles.

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116 views1 page

Tio Vs Videogram

The case Tio vs. Videogram Regulatory Board challenges the constitutionality of PD 1987, which established the Videogram Regulatory Board with powers to regulate the videogram industry, including tax provisions. The ruling determined that PD 1987 is constitutional, as its title and provisions are comprehensive and aligned with its regulatory purpose. The tax provision is deemed necessary for the regulation and rationalization of the video industry, as outlined in the decree's preambles.

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Insolent Potato
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Tio vs.

Videogram Regulatory Board, 151 SCRA 208

Facts:

1. Petitioner on his own behalf and purportedly on behalf of other videogram operators adversely affected
assailed the constitutionality of PD 1987 entitled "An Act Creating the Videogram Regulatory Board" with
broad powers to regulate and supervise the videogram industry. The Decree promulgated on October 5,
1985, took effect on April 10, 1986, fifteen (15) days after completion of its publication in the Official Gazette.

2. PD 1994 issued a month thereafter reinforced PD 1987 and in effect amended the National Internal Revenue
Code (NIRC). Petitioner contended among others that the tax provision of the decree is a rider.

ISSUE: Whether or not the PD 1987 is unconstitutional due to the tax provision included

RULING: PD 1987 is constitutional.

1. The title of the decree, which calls for the creation of the VRB is comprehensive enough to include the
purposes expressed in its Preamble and reasonably covered in all its provisions. It is unnecessary to express
all those objectives in the title or that the latter be an index to the body of the decree.

2. The foregoing provision is allied and germane to, and is reasonably necessary for the accomplishment of the
general object of the decree, which is the regulation of the video industry through the VRB as expressed in its
title. The tax provision is not inconsistent with nor foreign to the general subject and title. As a tool for
regulation it is simply one of the regulatory and control mechanisms scattered throughout the decree.

3. The express purpose of PD 1987 to include taxation of the video industry in order to regulate and rationalize
the heretofore uncontrolled distribution of videos is evident from Preambles 2 and 5. Those preambles
explain the motives of the lawmaker in presenting the measure.

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