Arroyo vs De Vencia

FACTS:
(This is about the validity of RA 8240 which amends certain provisions of the National Internal
Revenue Code)

Petitioners are members of the HOR brought a suit against respondents for violation of the rules
of the House which petitioners claim are “constitutionally mandated” so that their violation is
tantamount to a violation of the Constitution.

The law originated in the HOR as H. No. 7198 and was approved on third reading and transmitted
to the Senate which approved it with certain amendments. The bicameral conference committee
submitted its report to the House. After recess chairman of the committee proceeded to deliver
his sponsorship speech and Rep Sarmiento was first to interpellate. He was then interrupted by
Rep. Arroyo who moved to adjourn for lack of quorum but was declared that there was a presence
of a quorum. Re. Arroyo appealed but his motion was denied.

Rep. Arroyo announced that he was going to raise a question on the quorum, although until the
end of his interpellation he never did. (The Chair called out for objection to the motion. Then the
Chairman declared: “There being non, approved.” At the same time the Chairman was saying
this, Rep Arroyo was asking “What is that.. Mr. Speaker?” The Chair and Rep. Arroyo were talking
simultaneously. Thus, although Rep. Arroyo subsequently objected to the Majority Leader’s
motion, the approval of the conference committee report had by then already been declared by
the Chair.

On that same day the bill was signed by the Speaker of the HOR and the President of the Senate
and certified by the respective secretaries of both House of Congress as having been finally passed
by the HOR and Senate.

The enrolled bill was signed into law by President Ramos.

ISSUE:
1. WON the internal rules of procedure of the House have been violated in the enactment of
RA 8240
2. WON the enrolled bill doctrine, as a rule of evidence, is well established in this case.

RULING:
1.
SC decline the invitation to exercise their power. SC have no power to look into the internal
proceedings of a House than members of that House have to look over our shoulders, as long as
no violation of constitutional provisions is shown.

SC conclude the survey with the useful summary of the ruling of former Chief Justice
Fernando: Rules are hardly permanent in character. The prevailing view is that they are subject
to revocation, modification or waiver at the pleasure of the body adopting them as they are
primarily procedural. Courts ordinary have no concern with their observance. They may be waived
or disregarded by the legislative body. Consequently, mere failure to conform to them does not
have the effect of nullifying the act taken if the requisite number of members have agreed to a
particular measure. The above principle is subject, however, to this qualification. Where the
construction to be given to a rule affects person other than members of the legislative body the
question presented is necessarily judicial in character. Even its validity is open to question in a
case where private rights are involved.

In this case no rights of private individuals are involved but only those of a member who,
instead of seeking redress in the House, chose to transfer the dispute to this Court. Petitioners
must realize that each of the three departments of our government has its separate sphere which
the others may not invade without upsetting the delicate balance on which our constitutional
order rests.

2.
Under the enrolled bill doctrine, the signing of H. No. 7198 by the Speaker of the House and the
President of the Senate and the certification by the secretaries of both Houses of Congress that
it was passed on November 21, 1996 are conclusive of its due enactment.

But, where as here there is no evidence to the contrary, this Court will respect the certification of
the presiding officers of both Houses that a bill has been duly passed. Under this rule, this Court
has refused to determine claims that the three-fourths vote needed to pass a proposed
amendment to the Constitution had not been obtained, because "a duly authenticated bill or
resolution imports absolute verify and is binding on the courts."

The enrolled bill doctrine, as a rule of evidence, is well established. It is cited with approval by
text writers here and abroad. The enrolled bill rule rests on the following considerations:

. . . As the President has no authority to approve a bill not passed by Congress, an enrolled
Act in the custody of the Secretary of State, and having the official attestations of the
Speaker of the House of Representatives, of the President of the Senate, and of the
President of the United States, carries, on its face, a solemn assurance by the legislative
and executive departments of the government, charged, respectively, with the duty of
enacting and executing the laws, that it was passed by Congress. The respect due to
coequal and independent departments requires the judicial department to act upon that
assurance, and to accept, as having passed Congress, all bills authenticated in the manner
stated; leaving the court to determine, when the question properly arises, whether the
Act, so authenticated, is in conformity with the Constitution.

To overrule the doctrine now, as the dissent urges, is to repudiate the massive teaching of our
cases and overthrow an established rule of evidence.

The suggestion made in a case may instead appropriately be made here: petitioners can
seek the enactment of a new law or the repeal or amendment of R.A. No. 8240. In the absence
of anything to the contrary, the Court must assume that Congress or any House thereof acted in
the good faith belief that its conduct was permitted by its rules, and deference rather than
disrespect is due the judgment of that body.