Facts:

This case involves a petition for certiorari and/or prohibition filed by members of the House of Representatives, specifically Joker P. Arroyo, Edcel C. Lagman, John Henry R. Osmeña, Wigberto E. Tañada, and Ronaldo B. Zamora (petitioners), against Jose de Venecia (Speaker of the House), Raul Daza (Deputy Speaker), Rodolfo Albano (Majority Leader), the Executive Secretary, the Secretary of Finance, and the Commissioner of Internal Revenue (respondents). The petition, decided by the Supreme Court on August 14, 1997, challenges the validity of Republic Act No. 8240, which imposed specific taxes on the manufacture and sale of beer and cigarettes.

The case began in the House of Representatives, where H. No. 7198 was introduced and approved on third reading on September 12, 1996. It was subsequently transmitted to the Senate on September 16, 1996, and was approved there with amendments on November 17, 1996. A bicameral conference committee was established to resolve discrepancies betw

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Facts:

Background of the Case

• Petitioners, members of the House of Representatives, filed a petition for certiorari and/or prohibition challenging Republic Act No. 8240.
• RA No. 8240 amended certain provisions of the National Internal Revenue Code, imposing specific (asin) taxes on beer and cigarettes.
• The controversy arose from the alleged violation of internal House rules during the passage of the bill originating as House Bill No. 7198.

Legislative Process and Events on November 21, 1996

• The bill H. No. 7198 was approved on its third reading by the House on September 12, 1996 and transmitted to the Senate; the Senate approved it with certain amendments on November 17, 1996.
• A bicameral conference committee was formed to reconcile discrepancies between the House and Senate versions and submitted its report to the House on November 21, 1996 at 8 a.m.
• During the session on November 21, 1996, after a sponsorship speech and subsequent interpellation of the sponsor, procedural questions arose:
• Rep. Arroyo registered to interpellate and announced that he would raise a question regarding the quorum but did not do so during his speech.
• A transcript of the session is recorded in four different versions (via audio-sound recording, two certified transcripts from different dates, and the published version), which differ in specific details such as the presence or repetition of certain words or sentences.
• The sequence of events included:
• The Majority Leader, Mr. Albano, moved to approve and ratify the conference committee report.
• The Chair (Deputy Speaker Raul Daza) called for objections and, after no objection was noted, declared the report approved (signified by the gavel).
• Simultaneously, Rep. Arroyo raised a procedural query (“What is that, Mr. Speaker?”) which was not properly addressed.
• The session was suspended for a brief period and then later adjourned at 3:40 p.m. on the same day.

Certification and Enactment of the Law

• On November 21, 1996, the bill was certified as having been duly passed by both Houses of Congress.
• The enrolled bill was signed by the Speaker of the House and the President of the Senate on that very day and later signed into law by the President (Fidel V. Ramos) on November 22, 1996.

Allegations and Contentions by Petitioners

• Petitioners alleged that internal House rules were violated during the session, specifically:
• The manner of approval of the conference committee report—alleging that the motion was passed without a formal question on the quorum.
• The Chair’s alleged failure to call for a proper vote or to recognize Rep. Arroyo when he attempted to raise the quorum issue.
• The abrupt suspension and adjournment of the session intended to prevent Rep. Arroyo from formally questioning quorum.
• They contended that these violations amounted not only to a breach of House rules (which the Constitution grants each House the power to adopt) but also to a constitutional violation.
• Petitioners challenged the certification made by Speaker De Venecia as “false and spurious” based on these alleged procedural irregularities.
• They also sought a reexamination of the established enrolled bill doctrine, urging the Court to look behind the certification in view of alleged grave abuse of discretion.

Respondents’ Position

• Respondents defended the validity of the law by emphasizing:
• The principle of separation of powers, arguing that courts should not interfere in the internal proceedings of the legislative branch.
• That the enrolled bill doctrine gives conclusive effect to the certification of the bill as having been duly passed by both Houses.
• That the procedure adopted during the session was consistent with longstanding legislative practice, which had been applied in other similar instances.

Issue:

Whether the alleged violations of the internal rules of the House—particularly in the mode of approval of the conference committee report—rendered Republic Act No. 8240 null and void.

• Is the failure to conduct a formal vote for the conference committee report a constitutional violation or simply a breach of internal procedure?
• Does the handling of Rep. Arroyo’s inquiry on quorum constitute a denial of his privileges or rights as a House member?

Whether the court has jurisdiction to review and set aside legislative internal procedures and certification of the bill on the ground that they involve an abuse of discretion amounting to lack or excess of jurisdiction.

• Can the internal rules of a legislative body, adopted under the constitutional grant to determine its proceedings, be judicially enforced?
• Does the claim of grave abuse of discretion by the legislative branch justify judicial intervention?

Whether the enrolled bill doctrine is binding on the court, thereby precluding the inquiry into alleged procedural irregularities in the passage of the bill.

• Is the certification by the presiding officers of the House and Senate unequivocal proof of a law’s due enactment?
• May the court “look behind” the enrolled copy to verify compliance with constitutional requirements?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)