Primary Holding

The Supreme Court held that the validity of a constitutional amendment proposal, including whether it meets the required threshold, is a political question not subject to judicial review. The Court emphasized the "enrolled bill doctrine" and the separation of powers.

Background

The case arose after Congress passed a resolution proposing a constitutional amendment allowing American citizens and corporations to exploit natural resources in the Philippines, subject to a plebiscite for public ratification. Petitioners challenged this resolution, claiming it failed to meet the required three-fourths votes in both legislative chambers.

Facts

• 1. Following Philippine independence, Congress sought to amend the Constitution to allow American citizens and corporations to exploit Philippine natural resources under certain conditions.
• 2. On September 18, 1946, Congress passed a resolution proposing this constitutional amendment, requiring ratification through a plebiscite.
• 3. The amendment process required approval by three-fourths of all members of the Senate and House of Representatives, voting separately.
• 4. Petitioners, primarily members of Congress, alleged that the resolution failed to meet the required three-fourths vote due to the exclusion of certain suspended or invalidated members in the vote count.
• 5. They further argued that the exclusion of these lawmakers resulted in a procedural violation of the Constitution.
• 6. Respondents, including congressional leaders, asserted that the resolution was validly passed, as lawmakers excluded from the vote were either suspended or had not yet effectively assumed office.
• 7. The Supreme Court was asked to intervene to prevent the proposed plebiscite from being conducted on March 11, 1947.
• 8. The main contention was whether the resolution met constitutional requirements and whether the issue was justiciable by the judiciary.

Arguments of the Petitioners

• 1. The resolution failed to meet the constitutional requirement of approval by three-fourths of all members of the Senate and House of Representatives voting separately.
• 2. The exclusion of certain lawmakers from the count violated the Constitution.
• 3. Declaring the resolution valid would enable unconstitutional acts.

Arguments of the Respondents

• 1. Congress validly passed the resolution, as the excluded lawmakers were either suspended or not fully recognized as members.
• 2. The certified resolution enjoys the presumption of validity under the enrolled bill doctrine.
• 3. The issue involves a political question outside the Court's jurisdiction.

Issues

• 1. Whether the resolution proposing the constitutional amendment was validly passed under the three-fourths requirement.
• 2. Whether the exclusion of certain lawmakers violated their constitutional rights.
• 3. Whether the Supreme Court has jurisdiction over the matter or if it is a political question.

Ruling

• 1. The Supreme Court dismissed the petition, holding that the question of whether the resolution met the three-fourths voting requirement was a political question beyond the jurisdiction of the judiciary.
• 2. The Court ruled that it must defer to the legislative branch's certification of the resolution, invoking the enrolled bill doctrine, which presumes the validity of a legislative act certified by Congress leaders.
• 3. The Court emphasized that the Constitution grants Congress the authority to determine its internal proceedings, including voting thresholds for constitutional amendments.
• 4. It stated that judicial intervention in such matters would violate the principle of separation of powers.
• 5. The Court concluded that the proposed amendment's validity should ultimately be decided by the public in the scheduled plebiscite, not through judicial review.

Doctrines

• 1. Enrolled Bill Doctrine: Courts cannot question the validity of a law or resolution certified by the legislative leadership.
• 2. Political Question Doctrine: Matters involving interpretation and application of constitutional procedures for amending the Constitution are beyond judicial review.

Key Excerpts

• 1. "Political questions are not within the province of the judiciary."
• 2. "The stability of government depends upon the free and unobstructed privilege of the people to change their Constitution in the mode prescribed by the instrument."

Precedents Cited

• 1. Coleman v. Miller (307 U.S. 433): U.S. Supreme Court decision defining political questions as non-justiciable.
• 2. Green v. Weller (32 Miss. 650): Highlighted non-interference by courts in constitutional amendment processes.
• 3. Various rulings asserting the enrolled bill doctrine.

Statutory and Constitutional Provisions

• 1. Article XV, Section 1 of the Philippine Constitution: Requires amendments to be approved by three-fourths of all members of Congress voting separately.