Arroyo v. De Venecia
REITERATIONFacts
The Antecedents: Petitioners, members of the House of Representatives, filed a petition for certiorari and/or prohibition challenging the validity of Republic Act No. 8240, which imposed specific taxes on beer and cigarettes. The law originated in the House as H. No. 7198, was approved on third reading, transmitted to the Senate, and later reconciled by a bicameral conference committee. The conference committee report was submitted to the House on November 21, 1996. Procedural History: During the session on November 21, 1996, after the sponsorship speech and interpellation on the conference committee report, a motion to approve and ratify the report was made. While the Chair called for objections, Rep. Joker Arroyo raised a question. The Chair declared the report approved, and then suspended the session. The bill was subsequently signed into law by the Speaker, the Senate President, and the President of the Philippines. The Petition: Petitioners alleged that the law was passed in violation of the House rules, rendering it void. They claimed the certification of the Speaker was false and spurious, and that the proceedings were "railroaded," preventing Rep. Arroyo from questioning the quorum. They argued that House rules, being based on a constitutional mandate, are judicially enforceable. They also urged a re-examination of the enrolled bill doctrine.
Issue(s)
Whether Republic Act No. 8240 is null and void for alleged violation of the rules of the House of Representatives. Whether the Court can inquire into the internal proceedings of the House of Representatives regarding compliance with its own rules. Whether the enrolled bill doctrine is conclusive as to the due enactment of a law.
Ruling
The petition is DISMISSED. The Court found no ground to hold that Congress committed a grave abuse of discretion in enacting Republic Act No. 8240. The alleged violations pertained to internal rules of procedure, not constitutional requirements. The enrolled bill doctrine, supported by the House Journal, confirms the due enactment of the law.
Ratio Decidendi
On the alleged violation of House rules: The Court held that the alleged violations of the House rules in the enactment of Republic Act No. 8240 were merely internal procedural matters and not violations of constitutional requirements. The constitutional provision granting each House the power to determine its rules of proceedings (Art. VI, §16(3)) was established to ensure legislative autonomy, not to subject internal procedures to judicial review. The established jurisprudence, both domestic and foreign, denies courts the power to inquire into allegations that a House of Congress failed to comply with its own rules, unless a constitutional provision or the rights of private individuals are violated. The Court reiterated that parliamentary rules are procedural and may be waived or disregarded by the legislative body, and mere failure to conform to them does not invalidate an action taken if the requisite number of members agreed to it. The Court emphasized that it has no power to look into the internal proceedings of a House as long as no violation of constitutional provisions is shown, respecting the separation of powers among the three branches of government. On the Court's power to review internal legislative proceedings: The Court affirmed that its power under Article VIII, Section 1 of the Constitution to check for grave abuse of discretion does not extend to reviewing mere procedural irregularities within the legislative branch when no constitutional limits have been transgressed. The Court clarified that "grave abuse of discretion" implies a capricious and whimsical exercise of judgment amounting to a lack or excess of jurisdiction, which was not demonstrated in this case. The matter complained of concerned internal procedure, and the petitioners' claim that Rep. Arroyo was prevented from questioning the quorum was not a violation of a constitutional provision. The Court noted that Rep. Arroyo's earlier motion to adjourn for lack of quorum had already been defeated, and the question of quorum cannot be raised repeatedly to delay business. Furthermore, Rep. Arroyo's continued interpellation implied an acknowledgment of the quorum's presence. On the enrolled bill doctrine: The Court upheld the enrolled bill doctrine, stating that the signing of the bill by the Speaker of the House and the President of the Senate, and the certification by their respective secretaries that it was passed on a specific date, are conclusive of its due enactment. This doctrine rests on the respect due to co-equal and independent departments of government. The Court cited numerous cases, both domestic and foreign, that affirm the conclusiveness of an enrolled bill, absent evidence to the contrary. The Court also referred to the House Journal, which confirmed the approval of the conference committee report on the specified date, as further evidence of due enactment. The Court rejected the petitioners' plea to depart from this established rule based on a change in the Court's membership, emphasizing that to do so would repudiate massive jurisprudence and overthrow an established rule of evidence. The Court concluded that it would be an unwarranted invasion of a co-equal department's prerogative to set aside a legislative action based on alleged procedural missteps within the House.
Main Doctrine
The Court cannot inquire into allegations that a House of Congress failed to comply with its own rules of procedure in enacting a law, absent a showing of violation of a constitutional provision or the rights of private individuals. The enrolled bill doctrine presumes the regularity of legislative proceedings.