Arroyo vs.

De Venecia, 277 SCRA 268

Main Topic: Journals
Petitioners:
JOKER P. ARROYO, EDCEL C. LAGMAN, JOHN HENRY R. OSMEA, WIGBERTO E. TAADA, and
RONALDO B. ZAMORA

Respondents:
JOSE DE VENECIA, RAUL DAZA, RODOLFO ALBANO, THE EXECUTIVE SECRETARY, THE
SECRETARY OF FINANCE, AND THE COMMISSIONER OF INTERNAL REVENUE

Facts:
An amendment to the National Internal Revenue Code was introduced to the House
of Representatives involving taxations on the manufacture and sale of beer and
cigarettes. This was later passed accordingly and brought to the House of Senate. Upon
the interpellation on the second reading, herein petitioner moved for adjournment for
lack of quorum which is constitutionally needed to conduct business. Petitioners motion
was defeated and was railroaded. The bill was then signed into law by President Fidel
Ramos.
Issue:
Whether or not the law was passed on violation on the constitutional mandate.
Held:
There is no rule of the House concerned that quorum shall be determined by viva voce
or nominal voting. The Constitution does not require that the yeas and nays of the
Members be taken every time a House has to vote, except only on the following
instances upon the last and the third readings of the bill, at the request of 1/5 of the
Members present and in repassing a bill over the veto of the President. Second, there is
obviousness on the part of the petitioner to delay the business of the House, thus
eliminating the alleged skull doggery on part of the accused. Third the enrolled bill
doctrine states that enrolled bills are in it conclusive thus legally binding provided it is in
harmony with the constitution. Lastly, the court upheld principle of separation of powers,
which herein, is applicable for the legislative branch for it has exercised its power
without grave abuse of discretion resulting to lack or excess of jurisdiction