Monday, June 10, 2019

undue haste in declaring a law unconstitutional


R.A. No. 8050,[1] entitled "An Act Regulating the Practice of Optometry Education, Integrating Optometrists, and for Other Purposes,"otherwise known as the Revised Optometry Law of 1995, was a consolidation of House Bill (HB) No. 14100[2] and Senate Bill (SB) No. 1998,[3] which were respectively approved by both Houses and, thereafter, reconciled by the Bicameral Conference Committee.[4] The Reconciled Bill[5] was then separately ratified by both the Senate and the House of Representatives[6] and approved into law by the President on 7 June 1995.

On 31 July 1995, the private respondents filed with the Regional Trial Court (RTC) of Manila a petition for declaratory relief and for prohibition and injunction, with a prayer for a temporary restraining order.[7] As grounds for their petition, the private respondents alleged that:
1.  There were surreptitious and unauthorized insertion and addition of provisions in the Reconciled Bill which were made without the knowledge and conformity of the Senate panel, thereby derogating the orderly procedure essential to the legislative process and vitiating legislative consent;

2.  R.A. No. 8050 derogates and violates the fundamental right of every Filipino to reasonable safeguards against deprivation of life, liberty and property without due process of law in that it authorizes optometrists to engage in acts of practice within the zone of medical practice through permitted use in certain kinds of diagnostic pharmaceutical agents thereby exposing and subjecting those who avail of the services of optometrists to definite hazards which would inflict upon them impairment of vision, resultant blindness, or possible loss of life;

3.  R.A. No. 8050 derogates and violates the principle against undue delegation of legislative power when it provides for a penalty of imprisonment for a maximum of eight years and a fine not exceeding P40,000.00 upon any person found violating any rule or regulation promulgated pursuant to said law;

4.  R.A. No. 8050 suppresses truthful advertising concerning optical goods and services in violation of the guaranty of freedom of speech and press; and

5.  R.A. No. 8050 employs vague ambiguous terms in defining prohibitions and restrictions, hence, it falls within the ambit of void-for-vagueness doctrine which safeguards the guaranty of due process of law.


tHIRD DIVISION

[ G.R. No. 122241, July 30, 1996 ]

BOARD OF OPTOMETRY, REPRESENTED BY ITS CHAIRMAN, DR. PRIMITIVA Y. PEREZ-SISON, PROFESSIONAL REGULATION COMMISSION, REPRESENTED BY ITS COMMISSIONER, HERMOGENES P. POBRE, DEPARTMENT OF HEALTH, REPRESENTED BY ITS SECRETARY, DR. HILARION M. RAMIRO, BUREAU OF FOODS AND DRUGS, REPRESENTED BY ITS DIRECTOR, DR. QUINTIN L. KINTANAR, DEPARTMENT OF BUDGET AND MANAGEMENT, REPRESENTED BY ITS SECRETARY, SALVADOR M. ENRIQUEZ, JR., AND BUREAU OF HIGHER EDUCATION, REPRESENTED BY ITS DIRECTOR, MONA D. VALISNO, PETITIONERS, VS. HON. ANGEL B. COLET, PRESIDING JUDGE, REGIONAL TRIAL COURT OF MANILA, BRANCH 29, ACEBEDO OPTICAL COMPANY, INC., REPRESENTED BY ITS PRESIDENT AND CHAIRMAN OF THE BOARD, MIGUEL P. ACEBEDO, OPTOMETRY PRACTITIONERS ASSOCIATION OF THE PHILIPPINES (OPAP), REPRESENTED BY ITS PRESIDENT, DR. MIRIAM F. LLAVE, CENEVIS OPTOMETRIST ASSOCIATION (COA), REPRESENTED BY ITS PRESIDENT, DR. ROBERTO RODIS, JR., ASSOCIATION OF CHRISTIAN-MUSLIM OPTOMETRIST (ACMO), REPRESENTED BY ITS PRESIDENT, DR. CYRIL CORALES, SOUTHERN MINDANAO OPTOMETRIST ASSOCIATION OF THE PHILS., INC. (SMOAP), REPRESENTED BY ITS PRESIDENT, DR. ELMER VILLAROSA, AND REPUBLICA A. PANOL, NO. 9 GEN. MALVAR ST., ARANETA CENTER, CUBAO, QUEZON CITY, RESPONDENTS. 

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