Title
Arroyo vs. De Venecia
Case
G.R. No. 127255
Decision Date
Aug 14, 1997
Petitioners challenged Republic Act No. 8240, alleging House rule violations in its passage. The Supreme Court dismissed the case, upholding the enrolled bill doctrine and ruling that internal rule breaches do not invalidate laws unless constitutional provisions are violated.

Case Digest (G.R. No. 127255)
Expanded Legal Reasoning Model

Facts:

  • Background and Parties
    • Petitioners are five members of the House of Representatives (Reps. Joker P. Arroyo, Edcel C. Lagman, John Henry R. Osmeña, Wigberto E. Taada, Ronaldo B. Zamora).
    • Respondents are Speaker Jose de Venecia, Deputy Speaker Raul Daza, Majority Leader Rodolfo Albano, the Executive Secretary, the Secretary of Finance, and the Commissioner of Internal Revenue.
    • Petitioners filed a petition for certiorari and/or prohibition under Rule 65, challenging the validity of Republic Act No. 8240 (amending the National Internal Revenue Code with specific taxes on beer and cigarettes).
  • Legislative History of RA 8240
    • House Bill No. 7198 was approved on third reading in the House on September 12, 1996; transmitted to the Senate on September 16, 1996; Senate approved with amendments on November 17, 1996.
    • A bicameral conference committee reconciled differences; its report was submitted to the House on the morning of November 21, 1996.
  • Proceedings in the House on November 21, 1996
    • Rep. Exequiel Javier sponsored the conference report; Rep. Rogelio Sarmiento interpellated first.
    • Rep. Arroyo moved to adjourn for lack of a quorum; after roll call, quorum was declared; his appeal was defeated.
    • Majority Leader Albano moved to approve and ratify the conference committee report; the Chair called for objections, none were made, and the report was declared approved by motion.
    • Session was suspended briefly; upon resumption, Albano moved to adjourn until the following Wednesday; no objection, session adjourned at 3:40 p.m.
    • The enrolled bill was signed by presiding officers of both Houses and by the President on November 22, 1996, as RA 8240.
  • Transcript Variants and Petitioners’ Admissions
    • Petitioners obtained four versions of the transcript of the November 21 proceedings (audio recording, two certified transcripts, and the published version).
    • They observed discrepancies regarding the word “approved,” the number of times “no” appeared, and inclusion of a threat to “raise the question of the quorum.”
    • To expedite the case, petitioners admitted the correctness of respondents’ transcript and conceded the word “approved” appears therein.

Issues:

  • Procedural Issue
    • Whether RA 8240 was passed in violation of the House rules of procedure, which petitioners claim are constitutionally mandated under Art. VI, Sec. 16(3).
    • Whether such alleged violations of internal House rules render the law void or amenable to judicial review.
  • Doctrinal Issue
    • Whether the enrolled bill doctrine and the Journal entries of Congress conclusively establish the validity of RA 8240.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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