Title
Arroyo vs. De Venecia
Case
G.R. No. 127255
Decision Date
Jun 26, 1998
Petitioners challenged R.A. No. 8240's approval, alleging procedural violations in House session; SC upheld law, ruling no grave abuse of discretion.
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Case Digest (G.R. No. 127255)

Facts:

  1. Context of the Case:

    • Petitioners, including Joker P. Arroyo and other members of the House of Representatives, filed a petition for certiorari and prohibition challenging the approval of the conference committee report on the bill that became Republic Act (R.A.) No. 8240.
    • The petitioners alleged that the approval of the report was railroaded, as Rep. Arroyo’s question, “What is that, Mr. Speaker?” was ignored by the Chair (Deputy Speaker Raul Daza).
  2. Procedural Background:

    • During the House session on November 21, 1996, the Majority Leader (Rep. Rodolfo Albano) moved for the approval of the conference committee report.
    • The Chair asked if there were any objections to the motion. Rep. Arroyo stood up and asked, “What is that, Mr. Speaker?” without first being recognized by the Chair.
    • The Chair did not hear Rep. Arroyo and proceeded to declare the report approved after hearing no objections.
  3. Petitioners’ Claims:

    • Rep. Arroyo argued that his question was a privileged question or a point of order, which should have precedence over other matters under the House Rules.
    • Petitioners also claimed that the Chair failed to comply with House Rules requiring the Chair to state the motion and ask for individual votes, instead of merely asking for objections.
  4. Respondents’ Position:

    • The respondents, including the House leadership, argued that Rep. Arroyo did not follow proper parliamentary procedure by failing to request recognition before speaking.
    • They also defended the practice of asking for objections as a well-established parliamentary procedure.
  5. Subsequent Events:

    • After the session was suspended, Rep. Arroyo did not pursue his objection further. The bill was signed into law as R.A. No. 8240 the following day.

Issue:

  1. Whether Rep. Arroyo’s question, “What is that, Mr. Speaker?” constituted a privileged question or a point of order that should have been recognized by the Chair.
  2. Whether the Chair’s failure to state the motion and ask for individual votes violated the House Rules.
  3. Whether the approval of the conference committee report was railroaded, rendering R.A. No. 8240 invalid.
  4. Whether the Court can invalidate a law based on alleged violations of internal House Rules.

Ruling:

The Supreme Court denied the petitioners’ motion for rehearing and reconsideration, upholding its earlier decision dismissing the petition. The Court ruled that:

  1. Rep. Arroyo did not follow proper parliamentary procedure by failing to request recognition before speaking. His question was not a privileged question or a point of order.
  2. The Chair’s practice of asking for objections to the motion for approval of the conference committee report was consistent with established parliamentary procedure.
  3. The approval of the conference committee report was not railroaded, and there was no grave abuse of discretion by the House of Representatives.
  4. Alleged violations of internal House Rules do not affect the validity of R.A. No. 8240, as these rules are not constitutional requirements for the enactment of laws.

Ratio:

  1. Parliamentary Procedure:

    • Under the House Rules, a member must request recognition from the Chair before speaking. Rep. Arroyo failed to do so, and his question was not a privileged question or a point of order.
    • A question of privilege pertains to matters affecting the rights, duties, or reputation of the House or its members, while a point of order relates to objections to pending proceedings for violating House Rules.
  2. Established Practice:

    • The practice of asking for objections to the motion for approval of a conference committee report is a well-established parliamentary procedure. It is not a violation of House Rules.
  3. Judicial Review of Legislative Acts:

    • The Court’s power to review legislative acts is limited to determining whether there was grave abuse of discretion. In this case, no such abuse was found.
    • Internal House Rules are not constitutional requirements, and their alleged violation does not invalidate a law.
  4. Finality of Legislative Acts:

    • Once a bill is signed into law, it is presumed valid. Alleged procedural irregularities in the legislative process do not affect the validity of the law unless they involve constitutional violations.


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