G.R. No. 179061 - Matrido vs. People

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G.R. No. 179061: Matrido vs. People

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Title Source: Supreme Court: Tolentino vs. Secretary of Fice

Case: G.R. No. 115455

Decision Date: Oct 30, 1995

Multiple petitioners challenged R.A. No. 7716's constitutionality, alleging violations of revenue bill origination, due process, equal protection, and press freedom. The Supreme Court upheld the law, ruling the Senate's amendments, presidential certification, and legislative process were valid.

Case Digest (G.R. No. 179061)
Expanded Legal Reasoning Model

Facts:

Parties and Subject Matter

Petitioners: Multiple groups and individuals (including Arturo M. Tolentino, Juan T. David, Raul S. Roco & IBP, Philippine Press Institute, CREBA, Kilosbayan, Philippine Airlines, Cooperative Union, Philippine Educational Publishers Ass’n) challenged R.A. No. 7716 (Expanded Value-Added Tax Law).
Respondents: Executive Secretary, Secretary of Finance, Commissioner of Internal Revenue, Commissioner of Customs, and their agents.

Procedural History

Original petitions (G.R. Nos. 115455; 115525; 115543; 115544; 115754; 115781; 115852; 115873; 115931) sought declaration of unconstitutionality of R.A. No. 7716.
SC En Banc dismissed the petitions; ten motions for reconsideration (except in G.R. No. 115931) were filed.
Solicitor General filed consolidated comment; several petitioners filed replies; rejoinder by Solicitor General; case submitted for resolution on June 27, 1995.

Legislative Enactment of R.A. No. 7716

House Bill No. 11197 passed three readings in the House; sent to Senate and referred to Senate Ways and Means Committee.
Senate enacted its version (S. No. 1630) by substitution; certified “taking into consideration” H.B. 11197.
Conference Committee reconciled H.B. 11197 and S. No. 1630; enrolled bill certified by the President for immediate enactment; R.A. No. 7716 signed into law.

Issues:

Origination and Amendment of Revenue Bills

Whether Art. VI, § 24 requires the Senate to amend House revenue bills only by striking out and substituting text within the same bill.
Whether the Senate’s enactment of S. No. 1630 as a separate substitute violated the “originate exclusively” clause.

Presidential Certification

Whether the President’s certification for immediate enactment applied validly to a Senate substitute bill.
Whether “public calamity or emergency” was shown for certifying E.V.A.T. law.

Conference Committee Procedures

Whether executive-session meetings of the Conference Committee violated public’s right to know (Art. II, § 28; Art. III, § 7).
Whether the Conference Committee exceeded its jurisdiction by introducing new provisions.

Single Subject and Title Requirement

Whether R.A. No. 7716 violated Art. VI, § 26(1) by failing to express the amendment of specific exemptions (e.g., P.D. No. 1590) in its title.
Whether broad title language suffices to cover amendments of various NIRC provisions.

Press Freedom and Religious Liberty

Whether removal of VAT exemption from press entities discriminates against freedom of the press.
Whether VAT on Bible sales by Philippine Bible Society unduly burdens religious exercise.

Contracts, Due Process, Equal Protection, Progressive Taxation

Whether imposition of VAT on existing installment contracts impairs contractual obligations (Art. VI, § 10).
Whether VAT classifications are unreasonable or violate uniformity/equity and mandate to “evolve a progressive system of taxation” (Art. VI, § 28).

Policy on Cooperatives

Whether constitutional policy requiring support for cooperatives (Art. XII, §§ 1, 15) mandates VAT exemption.
Whether disparate treatment of electric versus other cooperatives violates equal protection.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

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END