Case Summary (A.C. No. 12289)
Issue: Interpretation and Validity of Section 10 of the Police Act of 1966
The core question concerns the correct interpretation and authenticity of Section 10 of the Police Act of 1966, which prescribes the minimum qualifications for appointment as chief of a city police agency. Petitioner Morales challenges the official version of the provision as contained in the enrolled bill, claiming discrepancies in the legislative history and alleging improper omission of certain qualifying phrases originally included in the Senate-approved text.
Legislative History and Contentions Regarding Section 10
Initially, the Senate Committee on Government Reorganization submitted a substitute bill wherein Section 10 required that no person may be appointed chief of a city police agency unless he held a bachelor’s degree and had served in either the Armed Forces of the Philippines, the National Bureau of Investigation, or the police department of any city, holding at least the rank of captain for three years. Alternatively, a high school graduate with at least eight years in similar ranks within the police department was also qualified. Senator Francisco Rodrigo proposed an amendment adding the phrase “has served as officer in the Armed Forces.” This amendment was intended to allow high school graduates with at least eight years of service as officers in the Armed Forces holding the rank of captain or higher to qualify.
Petitioner Morales argued this amended Senate version, which included the phrase “who has served the police department of a city or,” was approved on third reading and was altered only in the engrossment stage, where the phrase was omitted without Congressional authority. Petitioner submitted certified copies supporting his claim that the version approved by Congress originally contained the omitted phrase.
Judicial Ruling on Legislative Authenticity and the Enrolled Bill Doctrine
The Supreme Court emphasized the principle of judicial respect for legislative acts and the finality of the enrolled bill. The Court held that it cannot look beyond the enrolled bill’s contents to explore legislative history or alleged procedural discrepancies. The enrolled bill, as attested by the signatures of the presiding officers of both Houses of Congress and the President, constitutes conclusive and unimpeachable evidence of the law’s final form. The omission of the contested phrase, whether accidental or deliberate during the proofreading or engrossment phase, was not grounds for judicial interference.
The Court underscored the importance of separation of powers, holding that any inquiry into the correctness of the legislative text post-enrollment is beyond its jurisdiction and is instead a matter best addressed by Congress itself. The judiciary must avoid becoming a fact-finder concerning legislative proceedings that would undermine legislative integrity.
Precedential Support: US and Philippine Jurisprudence on Enrolled Bill Theory
The Court referenced American decisions, notably Marshall Field & Co. v. Clark and Harwood v. Wentworth, which held that the authenticity of an enrolled bill signed by legislative officers is conclusive in judicial proceedings. Similarly, Philippine decisions such as Mabanag v. Lopez-Vito and Casco Philippine Chemical C
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Facts and Procedural Posture
- Petitioner Enrique contested the qualification requirements set forth in Section 10 of the Police Act of 1966 regarding the appointment as chief of a city police agency.
- The case arose due to discrepancies in the legislative evolution of the said provision, particularly concerning the inclusion and subsequent omission of phrases relevant to qualification criteria.
- Petitioner filed motions for reconsideration of the Court's decision that upheld the existing text of Section 10, as officially enrolled and published.
- Petitioner relied heavily on certified photostatic copies of various drafts of House Bill 6951 and purported page proofs indicating the legislative intent and history, including amendments by Senator Francisco Rodrigo.
- Petitioner alleged that specific legislative language beneficial to his qualification was removed during bill engrossment, and argued that such deletion altered the substantive meaning of the law.
Legislative History and Amendments of Section 10
- The original Senate substitute bill introduced a minimum qualification requiring a bachelor's degree, with service in either the Armed Forces of the Philippines (AFP), National Bureau of Investigation (NBI), or a city police department at the rank of captain or equivalent for at least three years.
- An alternative qualification was for high school graduates with eight years of service in a city police department also with rank of captain or higher.
- Senator Francisco Rodrigo inserted the phrase "has served as officer in the Armed Forces" to expand qualifications to include such officers for at least 8 years.
- However, during legislative proceedings, the phrase “who has served the police department of a city or” was dropped, retaining only the Rodrigo amendment.
- Petitioner's submitted page proofs and a Senate bill division memorandum indicated that this phrase was present in the versions passed by both Houses, but was removed during the final engrossment stage.
- The final official Section 10 reads as follows: requiring a bachelor's degree and