G.R. No. L-23475 - Astorga vs. Villegas

Legislative History of House Bill No. 9266
On March 30, 1964, House Bill No. 9266 (local bill) was filed in the House of Representatives.
The House passed it on third reading without amendments on April 21, 1964, and transmitted it to the Senate.
The Senate Committee on Provinces and Municipal Governments favorably recommended the Roxas amendment (succession by President Pro Tempore), but on the floor (May 20, 1964) Senator Tolentino introduced and had approved substantial amendments to Section 1.
On May 21, 1964, the Senate Secretary certified only the Roxas amendment (omitting Tolentino’s), and the House approved the enrolled copy accordingly. Four printed copies were signed by presiding officers and secretaries of both Houses and sent to the President.
The President affixed his signature on June 18, 1964, and the bill became Republic Act No. 4065, defining the powers, rights, and duties of the Vice-Mayor of Manila.

Post-Enactment Controversy and Judicial Proceedings
On July 5, 1964, Senator Tolentino publicly declared the enrolled copy defective for omitting his approved amendments.
The Senate President, by letters dated July 11 and July 21, 1964, invalidated his signature and stated the enrolled bill was never duly approved by the Senate.
On July 31, 1964, the President of the Philippines withdrew his signature, deeming it “untenable” to convert into law a bill not actually approved by both Houses.
Mayor Villegas issued circulars directing city officials and business operators in Manila to disregard RA 4065 and ordered the recall of police officers assigned to the Vice-Mayor under the Act.
On September 7, 1964, Vice-Mayor Astorga filed a petition for mandamus, injunction, and prohibition to compel compliance with RA 4065.
Respondents contended that RA 4065 never became law, and that the enrolled-bill doctrine precluded resort to Senate journal entries.
On April 28, 1965, the Court issued a temporary restraining order enjoining Astorga from exercising powers under the challenged Act.

Validity of RA 4065
Whether RA 4065 was duly enacted into law despite discrepancies between the enrolled copy and Senate journal entries.
Whether the petitioners may invoke the enrolled-bill doctrine to preclude examination of journal records.

Effect of Disavowals by Senate President and President
Whether the Senate President’s invalidation of his attestation nullified the enrolled bill.
Whether the President’s withdrawal of his signature rendered RA 4065 void ab initio.