Astorga vs. Villegas

Facts:

On March 30, 1964 House Bill No. 9266 (a local bill) was filed in the House of Representatives and was passed by the House on third reading on April 21, 1964. The bill was transmitted to the Senate, referred to the Committee on Provinces and Municipal Governments and Cities, and the committee recommended approval with a minor amendment (substituting the President Pro Tempore of the Municipal Board for the City Engineer as successor to the Vice‑Mayor) suggested by Senator Gerardo M. Roxas.

When the bill reached the Senate floor for second reading on May 20, 1964, Senator Arturo Tolentino introduced substantial amendments to Section 1 which the Senate approved. The Senate Secretary, however, sent a letter to the House dated May 21, 1964 certifying that the bill was passed “with amendments” and attached a certification that reflected the Roxas committee amendment rather than the Tolentino floor amendments actually approved by the Senate.

The House accepted the enrolled printed copies as transmitted and the Secretary of the House forwarded certified printed copies to the President. The President signed the printed bill on June 18, 1964, whereupon it was titled Republic Act No. 4065. Public controversy followed: Senator Tolentino publicly stated the enrolled copy did not reflect the amendments the Senate adopted; the Senate President, through the Senate Secretary, wrote the President (July 11, 1964) declaring the enrolled bill signed and sent to the President was not the bill duly approved by the Senate, and on July 21, 1964 clarified that his signature on the enrolled bill was invalid and thus the bill he had signed had never been approved by the Senate.

The President then withdrew his signature on the enrolled copy (message to presiding officers, July 31, 1964), stating it would be untenable to convert into law what was not actually approved by both Houses. Following these developments, Mayor Antonio J. Villegas issued circulars directing city officials and business owners in Manila to disregard the provisions of R.A. 4065 and ordered the Chief of Police to recall policemen assigned pursuant to the alleged statute.

Reacting to the Mayor’s acts, Vice‑Mayor Herminio A. Astorga filed a petition in the Supreme Court on September 7, 1964 for mandamus, injunction and/or prohibition, seeking to compel compliance with R.A. 4065. Respondents contended R.A. 4065 never became law because the enrolled bill did not contain the text actually passed by the Senate, and that the Senate journal entries should control.

On April 28, 1965 the Court issued a restraining order (without bond) enjoining Astorga from exercising powers purportedly conferred by R.A. 4065 pending further orders. The case raised the question whether the Court should follow the “enrolled bill” doctrine (treating an authenticated enrolled bill as conclusive proof of enactment) or instead examine the jour...(Pro-only)

Issues:

• Whether the enrolled bill doctrine precludes judicial inquiry into the due enactment of a statute where a presiding officer of a House of Congress disavows his attestation of the enrolled bill.
• Whether Republic Act No. 4065 was duly enacted and theref...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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