Astorga v. Villegas
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the validity of Republic Act No. 4065, an act intended to define the powers, rights, and duties of the Vice-Mayor of Manila, by amending specific sections of the Revised Charter of the City of Manila. The controversy arose due to discrepancies between the version of the bill passed by the Senate and the enrolled copy that was presented to and signed by the President. 2. Procedural History: House Bill No. 9266 was passed by the House of Representatives and sent to the Senate. The Senate introduced substantial amendments, which were approved. However, the enrolled copy sent to the President, and subsequently signed by him, did not include these Senate amendments. The Senate President declared his signature on the enrolled bill invalid, and the President subsequently withdrew his signature. The Mayor of Manila then issued circulars to disregard the provisions of Republic Act 4065. In response, the Vice-Mayor of Manila filed a petition with the Supreme Court seeking to compel compliance with the Act. 3. The Petition: The petitioner, Herminio A. Astorga, in his capacity as Vice-Mayor of Manila, filed a petition for Mandamus, Injunction and/or Prohibition with Preliminary Mandatory and Prohibitory Injunction. The petition sought to compel the respondents, including the Mayor of Manila, the Executive Secretary, the Commissioner of Civil Service, the Chief of Police, the City Treasurer, and members of the Municipal Board, to comply with the provisions of Republic Act 4065. The core of the petition argued for the validity of the enrolled bill, while the respondents contended that the journal entries should prevail over the enrolled bill due to the Senate's amendments not being reflected in the final version.
Issue(s)
Whether Republic Act No. 4065, as authenticated and signed by the President, is a valid law despite allegations that it did not contain the substantial amendments approved by the Senate. Whether the enrolled bill doctrine or the journal entry rule should prevail in determining the validity of a statute in the Philippines.
Ruling
The petition is denied. Republic Act No. 4065 is declared not to have been duly enacted and therefore did not become law. The temporary restraining order is made permanent.
Ratio Decidendi
On the validity of Republic Act No. 4065: The Court held that the enrolled bill doctrine, while generally respected due to the principle of separation of powers and respect for co-equal branches, is not an absolute bar to judicial inquiry. In this specific case, the integrity of the enrolled bill was compromised by the Senate President's declaration that his signature was invalid because the bill signed was not the one approved by the Senate. This was further corroborated by the President of the Philippines withdrawing his signature. The Court found that the enrolled copy presented to the President did not contain the substantial amendments approved by the Senate on the floor, thus it was not the bill duly enacted by Congress. To uphold the erroneous enrolled bill would be to sacrifice truth to fiction and lead to unintended consequences. On the enrolled bill doctrine versus the journal entry rule: The Court acknowledged the differing opinions on this matter, referencing the case of Mabanag vs. Lopez Vito. While the enrolled bill doctrine, supported by Section 313 of Act 190 (as amended), provides that a certified copy signed by presiding officers and secretaries is conclusive proof of due enactment, this conclusiveness is not absolute, especially when the authenticity of the attestation itself is questioned. The Court noted that the Constitution requires each House to keep a journal of its proceedings. In situations where the enrolled bill's authenticity is in doubt, particularly when the legislative and executive branches themselves acknowledge an error, resorting to the legislative journals becomes necessary to ascertain the true will of Congress. The journal entries in this case clearly showed that substantial amendments were approved by the Senate but were omitted from the final enrolled bill, thus demonstrating that the bill signed by the President was not the one passed by Congress.
Main Doctrine
The enrolled bill doctrine, which presumes the validity of a statute based on its authentication by legislative officers, is not absolute. In cases of manifest error or dispute regarding the actual text passed by Congress, the Court may resort to legislative journals to ascertain due enactment, especially when the authenticity of the enrolled bill is questioned by the legislative or executive branches themselves.