Primary Holding

The Supreme Court held that the alleged violations of House rules in the passage of R.A. No. 8240 did not amount to a constitutional violation. The Court also reaffirmed the enrolled bill doctrine, which presumes the validity of a law once it has been duly enacted and certified by the legislative and executive branches.

Background

The case arose from the passage of R.A. No. 8240, which amended the National Internal Revenue Code to impose specific taxes on beer and cigarettes. Petitioners, members of the House of Representatives, claimed that the law was passed in violation of House rules, particularly regarding the approval of the conference committee report and the handling of quorum issues.

Facts

• 1. Petitioners alleged that the approval of the conference committee report violated House rules, particularly Rule VIII, §35, Rule XVII, §103, Rule XIX, §112, Rule XVI, §97, and Rule XX, §§121-122.
• 2. Petitioners claimed that Rep. Arroyo was prevented from questioning the quorum and that the session was hastily adjourned to prevent a formal challenge.
• 3. The House Journal showed that the conference committee report was approved on November 21, 1996, and the bill was signed into law the next day.

Arguments of the Petitioners

• 1. The law was passed in violation of House rules, which they claimed were constitutionally mandated.
• 2. The Chair ignored Rep. Arroyo's objection and did not restate the motion for approval, violating House rules.
• 3. The session was adjourned hastily to prevent Rep. Arroyo from formally challenging the quorum.

Arguments of the Respondents

• 1. The Court should not interfere with the internal rules of the House, as they are not constitutional requirements.
• 2. The enrolled bill doctrine presumes the validity of the law, and the Court should respect the certification of the Speaker and the President.
• 3. The House rules were followed, and the approval of the conference committee report was in line with legislative practice.

Issues

• 1. Whether the passage of R.A. No. 8240 violated the House rules and, consequently, the Constitution.
• 2. Whether the enrolled bill doctrine should be upheld.

Ruling

• 1. The Court ruled that the alleged violations were internal procedural matters and did not amount to a constitutional violation.
• 2. The Court upheld the enrolled bill doctrine, stating that the certification of the Speaker and the President is conclusive evidence of the law's due enactment.
• 3. The Court emphasized the principle of separation of powers and the need for judicial restraint in matters of internal legislative procedure.

Doctrines

• 1. Enrolled Bill Doctrine: A duly authenticated bill is conclusive evidence of its due enactment and cannot be impeached by the courts.
• 2. Separation of Powers: Courts should not interfere with the internal procedures of the legislative branch unless there is a clear constitutional violation.

Key Excerpts

• 1. "The respect due to coequal and independent departments requires the judicial department to act upon that assurance, to accept, as having passed Congress, all bills authenticated in the manner stated."
• 2. "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."
• 3. “We have no more 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.”

Precedents Cited

• 1. Tolentino v. Secretary of Finance (235 SCRA 630): Reaffirmed the enrolled bill doctrine.
• 2. Osmeña v. Pendatun (109 Phil. 863): Held that courts have no concern with parliamentary rules.
• 3. United States v. Ballin (144 U.S. 1): Established that courts cannot inquire into the validity of legislative rules unless they violate constitutional restraints.
• 4. Astorga v. Villegas - Limited exceptions to the enrolled bill doctrine.

Statutory and Constitutional Provisions

• 1. Article VI, §16(3): Each House may determine the rules of its proceedings.
• 2. Article VI, §26(2): No amendment shall be allowed upon the last reading of a bill.
• 3. Article VIII, §1: Judicial power includes the duty to determine whether there has been a grave abuse of discretion amounting to lack or excess of jurisdiction.