Case Digest (G.R. No. L-29658)
Facts:
The case is Enrique v. Morales, G.R. No. L-29658, February 27, 1969, the Supreme Court (no division indicated), Castro, J., writing for the Court. The petition before the Court concerned motions for reconsideration filed by Enrique (petitioner) directed at a portion of this Court's prior decision involving the construction and authenticity of Section 10 of the Police Act of 1966; Abelardo Subido, as Commissioner of Civil Service, was respondent in the underlying controversy.
Petitioner presented certified photostatic copies of various drafts of House Bill No. 6951, including page proofs and a memorandum from a Senate bill-division employee, to show that the language of Section 10 as finally enrolled differed materially from earlier drafts. Specifically, petitioner alleged that a phrase — "who has served the police department of a city or" — which would have enabled his qualification under one clause, had been omitted during proofreading/engrossment and that the only retained change was a later Rodrigo amendment. Petitioner thus contended that the enrolled Act as printed did not reflect what Congress actually approved and that the Court should examine the legislative papers to correct or annul the provision.
The Court had earlier issued a decision rejecting petitioner’s contention; the present filing were motions for reconsideration of that decision. In the resolution now before the Court, the justices addressed whether the judiciary may go behind an enrolled Act by entertaining external legislative papers and proofs to impeach the text of an enrolled statute and whether the enrolled bill doctrine precludes such inquiry. The Court considered United States and Philippine precedents (notably Marshall Field & Co. v. Clark, Harwood v. Wentworth, Mabanag v. Lopez-Vito, and Casco Philippine C...(Subscriber-Only)
Issues:
- May the judiciary go behind an enrolled Act and examine legislative drafts, page proofs, or internal memoranda to prove that the statute as enrolled and authenticated differs from the measure actually passed by the legislature?
- Is an enrolled bill (authenticated by the presiding officers of the houses and approved by the President) conclusive and binding upon the courts, thereby precluding judicial inquiry into alleged discrepancies...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)