Case Summary (G.R. No. 133240)
Legislative History of R.A. No. 8240
House Bill No. 7198 originated in the House, passed third reading on September 12, 1996, then went to the Senate, where it was amended and approved on November 17, 1996. A bicameral conference committee reconciled differences and reported back to the House on the morning of November 21, 1996.
Quorum Dispute During Final House Session
On November 21, petitioners moved to adjourn for lack of quorum during interpellation. A roll‐call established a quorum, and interpellation continued. When Majority Leader Albano moved to approve the conference report by motion and “calling for any objection,” Rep. Arroyo attempted to object and query the Chair, but the Chair declared “there being none, approved” and gavelled the approval. The session was briefly suspended, then adjourned until the following week.
Multiple Transcript Versions and Petitioners’ Admissions
Petitioners initially alleged discrepancies among four transcript versions of the 3:00–3:40 p.m. proceedings, but, for expedition, they “admitted”—without conceding—accuracy of the transcripts relied upon by respondents, including the presence of the word “approved.”
Alleged Violations of House Rules
Petitioners asserted four specific breaches:
- Approval of the conference report without a yeas‐and‐nays call (Rules VIII, XVII)
- Failure to read or restate Albano’s motion (Rule XIX)
- Refusal to recognize Rep. Arroyo when he rose (Rule XVI)
- Suspension and adjournment without ruling on Arroyo’s query (Rules XX–XXI, XVIII)
Respondents’ Certification and Journal Defense
Respondents denied any manipulation, invoked the enrolled bill doctrine and the House’s journal entry (Journal No. 39), which records: “On motion of Mr. Albano, there being no objection, the Body approved the Conference Committee Report on House Bill No. 7198.” That journal was duly approved by the House, barring inquiry under the journal‐entry rule.
Nonjusticiability of Internal Legislative Rules
The Court held that the petition concerns mere internal procedural rules, not constitutional requirements for lawmaking (e.g., three readings on separate days, quorum presence under Art. VI, Secs. 26–27). Precedents both domestic and foreign uniformly refuse to invalidate legislative acts for noncompliance with their own procedural rules in the absence of a constitutional violation or infringement of private rights.
No Grave Abuse of Discretion Under Art. VIII, Sec. 1
Petitioners’ reliance on the Court’s power to review “grave abuse of discretion amounting to lack or excess of jurisdiction” was unavailing. There was no overreach by any respondent that would satisfy this strict standard.
Validation of Approval‐by‐Motion Practice
The Court recognized longstanding legislative practice permitting approval of conference reports by motion and “no objection,” without a roll-call vote or restatement of the motion, so long as a quorum actually exists. Such methods are within the House’s discretion and are not for judicial second-guessing.
Adjournment and Waiver of Objections
The brief suspension and adjournment of the session were legitimate, and Arroyo’s continued interpellation and failure to object upon resumption amounted to waiver of any procedural claim. Had he raised a privileged point or point of order, adjournment would still have prevailed.
Separation of Powers and Judicial Restraint
The Court underscored respect for the coordinate legislative department and the need for judicial restraint in inquiries into internal legislative affairs, absent cons
Case Syllabus (G.R. No. 133240)
Background of the Petition
- Petitioners, all members of the House of Representatives, filed for certiorari and/or prohibition
- Challenge to Republic Act No. 8240, which imposed specific taxes on beer and cigarettes by amending the National Internal Revenue Code
- Petitioners alleged that respondents violated House Rules that are, in their view, “constitutionally mandated,” thus rendering the law’s enactment unconstitutional
Legislative History of RA 8240
- Originated as House Bill No. 7198; approved on third reading by the House on September 12, 1996
- Transmitted to the Senate on September 16, 1996; Senate approved with amendments on November 17, 1996
- Bicameral conference committee convened; report submitted to the House on November 21, 1996 at 8:00 a.m.
- After interpellation and motions, Speaker and Senate President signed the enrolled bill the same day
- President Fidel V. Ramos signed it into law on November 22, 1996
Disputed Proceedings on November 21, 1996
- Sponsorship speech by Rep. Exequiel Javier followed by interpellations; Rep. Arroyo moved to adjourn for lack of quorum but was defeated after head count
- Transcripts of 3:00–3:40 p.m. session exist in four versions with minor discrepancies (inaudible “approved,” repetition of “no,” omitted quorum warning)
- Petitioners ultimately admitted correctness of respondents’ transcript to expedite resolution
Petitioners’ Contentions
- RA 8240 passed in violation of House Rules VIII, XVII, XIX, XVI, XX, XXI, and XVIII regarding:
• Calling of yeas and nays on conference committee reports
• Stating and reading of motions before debate
• Recognition of members entitled to speak
• Handling of questions of privilege, points of order, and adjournment motions - Certification by Speaker de Venecia that the law was properly passed is “false and spurious”
- Chair “railroaded” approval to prevent Rep. Arroyo from formally raising quorum question
Respondents’ Defense
- Enforcement of internal House rules is not subject to judicial review, except where they implement con