Case Summary (G.R. No. L-29658)
Factual Background
The dispute arose from differing textual versions of section 10 of House Bill 6951, the provision prescribing minimum qualifications for appointment as chief of a city police agency. The petitioner claimed that a Senate substitute and a subsequent amendment by Senator Francisco Rodrigo produced a version that would permit him, as at least a high school graduate who had served in municipal police or the Armed Forces, to qualify for appointment. The petitioner produced certified photostatic drafts and page proofs of the bill showing that the phrase "who has served the police department of a city or" appeared in earlier drafts but that the final enrolled Act omitted that phrase and presented a different arrangement of disjunctive qualifications. The petitioner also produced a certified memorandum purportedly from a Senate bill division employee stating that section 10 was "recast for clarity," and he contended that the omission occurred during proofreading or engrossment by legislative staff rather than by deliberate legislative action.
The Parties' Contentions
The petitioner urged that the Senate-approved textual formulation, incorporating the Rodrigo amendment and the phrase enabling municipal police service to qualify, had been altered after legislative approval so as to exclude his qualifying clause, and that the Court should examine the bill's legislative history and the alleged proofreading alteration to determine the true legislative intent and correct text. The respondent and the governmental officers relied upon the enrolled Act on file with the legislative secretary and the officially published slip law as the authoritative text, and the Court treated the enrolled Act as conclusive, resisting the petitioner's invitation to probe clerical or proofreading practices.
Procedural Posture
The present resolution disposed of motions for reconsideration directed specifically at the portion of the Court's earlier decision addressing the textual discrepancy in section 10. The Court denied the motions for reconsideration and reaffirmed its prior holding that it would not go behind the enrolled Act to examine legislative drafts, committee reports, or internal annotations.
Ruling of the Court
The Court denied the motions for reconsideration. It held that the enrolled Act as authenticated in the office of the legislative secretary of the President and as published by the Bureau of Printing exactly reflected section 10 and that the judiciary could not entertain evidence aimed at demonstrating that the enrolled text differed from what the Congress actually passed. The Court refused the petitioner's request to investigate whether legislative staff had altered language in proofreading, stating that such an inquiry would impermissibly substitute judicial fact-finding for the conclusive attestation of legislative officers.
Legal Basis and Reasoning
The Court grounded its decision on the enrolled bill doctrine, as developed in Philippine jurisprudence and aligned with antecedent United States authorities. The Court reasoned that the signatures of the presiding officers of each house on the enrolled bill, and the President's signature and deposit in the archives, constituted an official attestation that the bill as enrolled was the one passed by Congress, and that this authentication was "complete and unimpeachable." The Court relied on Marshall Field & Co. v. Clark and Harwood v. Wentworth as controlling precedents establishing the impropriety of permitting parol or documentary evidence to displace the enrolled Act. The Court reviewed Philippine precedents adopting the enrolled bill theory, notably Mabanag v. Lopez-Vito and Casco Philippine Chemical Co. v. Gimenez, and affirmed that an enrolled bill "imports absolute verity and is binding on the courts." The Court emphasized separation-of-
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Parties and Posture
- ENRIQUE V. MORALES, PETITIONER moved for reconsideration of a prior decision of the Court concerning the construction of section ten of the Police Act of 1966.
- ABELARDO SUBIDO, AS COMMISSIONER OF CIVIL SERVICE, RESPONDENT opposed the motions and defended the form of the enrolled statute as published.
- The Court considered the motions for reconsideration and resolved the dispute by written resolution authored by Justice Castro.
Key Facts
- The controversy arose from differing drafts and page proofs of House Bill 6951 as it progressed through Congress.
- The drafts showed that a phrase, "who has served the police department of a city or," appeared in earlier versions and was omitted in the enrolled Act.
- The petitioner produced certified photostatic copies of drafts and a memorandum allegedly from a Senate bill-division employee explaining that section ten "was recast for clarity."
- The petitioner asserted that the omission was made inadvertently during engrossment or proofreading and that the Senate-approved wording had been altered.
Legislative History Evidence
- The petitioner presented page proofs showing the provision with the phrase "who has served the police department of a city or" still included.
- The petitioner submitted a certified photostatic copy of a memorandum attached to the page proofs stating that "Section 10 was recast for clarity."
- The enrolled Act, as attested in the office of the legislative secretary of the President and as published in slip form by the Bureau of Printing, omitted the disputed phrase.
Issue Presented
- The controlling issue was whether the Court could go behind the enrolled Act to examine legislative drafts, proofs, and internal memoranda in order to correct or impeach the content of an enrolled statute.
Petitioner’s Arguments
- The petitioner contended that the version approved by the Senate on third reading included the disputed phrase and that the version finally enacted was altered only during proofreading or engrossment.
- The petitioner asserted that proof from legislative drafts and memoranda demonstrated that the enrolled text did not reflect the true legislative will and therefore warranted judicial inquiry.
Respondent’s Position
- The respondent maintained that the text of the enrolled Ac