Case Digest (G.R. No. 115455)
Facts:
Arturo M. Tolentino v. The Secretary of Finance and the Commissioner of Internal Revenue, G.R. Nos. 115455, 115525, 115543, 115544, 115754, 115781, 115852, 115873, 115931, October 30, 1995, the Supreme Court En Banc, Mendoza, J., writing for the Court.Several petitioners (including Arturo M. Tolentino, Juan T. David, Raul S. Roco and the Integrated Bar of the Philippines, the Philippine Press Institute, Philippine Airlines, Inc., CREBA, Kilosbayan, Inc., Cooperative Union of the Philippines, and others) challenged the constitutionality of R.A. No. 7716 (the Expanded Value-Added Tax Law), asserting multiple constitutional defects in its enactment and substance. The petitions sought declarations of unconstitutionality and other reliefs; the Court earlier dismissed those petitions and issued a temporary restraining order enjoining enforcement of the law pending resolution. The present disposition concerns motions for reconsideration of that dismissal filed by ten of the petitioning parties (the Philippine Educational Publishers Association and the Association of Philippine Booksellers did not file a motion for reconsideration).
The Solicitor General, representing the respondents (the Secretary of Finance, the Commissioner of Internal Revenue, and other executive officers), filed a consolidated comment opposing reconsideration; several petitioners filed replies and the Solicitor General filed a rejoinder. The matter was submitted for resolution on June 27, 1995. The Court treated and resolved a set of recurring constitutional attacks grouped thematically: (1) the Senate’s power to propose amendments to House-originating revenue bills and the propriety of S. No. 1630 as an amendment/substitute to H. No. 11197; (2) the validity of the President’s certification for immediate enactment; (3) the conference committee’s executive sessions and compliance with disclosure obligations; (4) the bill’s title and one‑subject rule as to specific exemptions (e.g., Philippine Airlines); (5) claims invoking press freedom and religious liberty; (6) alleged impairment of cont...(Pro-only)
Issues:
- Did the Senate exceed its constitutional power to propose or concur with amendments to a revenue bill required to originate in the House by enacting S. No. 1630 instead of amending H. No. 11197 in form?
- Was the President’s certification of the bill for immediate enactment invalid because it was made with respect to the Senate version rather than the House version?
- Did the Conference Committee’s executive‑session meetings and the manner of reporting violate the public’s right to know and legislative rules?
- Did R.A. No. 7716 violate the constitutional one‑subject and title rule (Art. VI, Sec. 26(1)) insofar as it withdrew VAT exemptions (e.g., affecting Philippine Airlines) without expressly referencing the enabling special laws in the title?
- Do the withdrawal of exemptions and the imposition of the VAT on the press and religious distributors violate freedom of the press or free exercise of religion?
- Do the provisions of R.A. No. 7716 impair contract obligations or violate due process, equal protection and the constitutional command that taxation be uniform, equitable and progressive (Art. VI, Sec. 28(1))?
- Do constitutional provisions favoring cooperativ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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