Case Digest (G.R. No. 127255)
Facts:
Arroyo v. De Venecia, G.R. No. 127255, August 14, 1997, Supreme Court En Banc, Mendoza, J., writing for the Court. Petitioners are Joker P. Arroyo, Edcel C. Lagman, John Henry R. Osmeña, Wigberto E. Tanada, and Ronaldo B. Zamora, all Members of the House of Representatives; respondents include Jose De Venecia (Speaker), Raul Daza (Deputy Speaker), Rodolfo Albano (Majority Leader), the Executive Secretary, the Secretary of Finance, and the Commissioner of Internal Revenue.The challenged statute is Republic Act No. 8240 (the “sin taxes” on beer and cigarettes). The measure originated as House Bill No. 7198, approved by the House on third reading on September 12, 1996, transmitted to the Senate on September 16, 1996, and, after the Senate’s amendments, reconciled by a bicameral conference committee. The conference committee report was submitted to the House on November 21, 1996; during that day’s session Rep. Exequiel Javier sponsored the report and was interpellated. After several interpellations, Majority Leader Albano moved to “approve and ratify” the conference committee report; the Chair asked “Any objection?” and then declared the motion “approved” when, as recorded, Rep. Arroyo and the Chair spoke simultaneously. The House adjourned the same afternoon; the enrolled bill was certified by the presiding officers on November 21, 1996 and signed into law by the President on November 22, 1996.
Petitioners alleged multiple violations of House rules during the approval of the conference committee report (failure to take the yeas and nays, failure to repeat the motion, refusal to recognize a Member, suspension of session without ruling on a privileged question), and contended those infractions amounted to a constitutional defect in passage and rendered the Speaker’s certification false and R.A. No. 8240 void. They asserted the existence of conflicting transcripts and questioned whether a quorum was effectively challenged. Respondents denied any procedural or constitutional infirmity, invoked the separation of powers, and relied on the enrolled bill doctrine and the House Journal (Journal No. 39) showing the report was approved; the Solicitor General filed a consolidated comment.
Petitioners brought a petition for certiorari and/or prohibition (Rule 65) directly to the Supreme Court attacking the law’s validity. After full consideration of the sub...(Pro-only)
Issues:
- Is the Court authorized to entertain a petition seeking to invalidate a statute on the ground that a House of Congress violated its internal rules in passing it (i.e., are the alleged infractions of House rules justiciable or barred by separation of powers and the political-question doctrine)?
- Was Republic Act No. 8240 void for having been passed in violation of the House rules invoked by petitioners (including by denying a Member the opportunity to raise the question of quorum)?
- Does the enrolled bill doctrine (and the House Journal) preclude judicial inquiry into the due enactment of H.B. No...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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