Arroyo v. De Venecia
REITERATIONFacts
The Antecedents: Petitioners sought a rehearing and reconsideration of the Court's decision dismissing their petition for certiorari and prohibition. Their contention was that the Majority Leader moved for the approval of a conference committee report, and when Rep. Joker P. Arroyo asked "What is that, Mr. Speaker?", the Chair allegedly ignored him and declared the report approved. Petitioners claimed this question was a privileged question or a point of order with precedence over other matters. Procedural History: The original petition for certiorari and prohibition was dismissed by the Supreme Court. This case concerns the motion for rehearing and reconsideration of that dismissal. The Petition: Petitioners sought a rehearing and reconsideration of the Court's decision, arguing that the House of Representatives acted with grave abuse of discretion in approving the conference committee report that became R.A. No. 8240, due to alleged procedural irregularities.
Issue(s)
Whether the question "What is that, Mr. Speaker?" raised by Rep. Arroyo was a privileged question or a point of order. Whether the Chair ignored Rep. Arroyo when he raised his question. Whether the procedure for approving the conference committee report, which involved asking for objections rather than individual votes, violated House rules. Whether the questioning of quorum was repeatedly raised for the purpose of delaying the business of the House. Whether the alleged disregard of internal House rules in the enactment of R.A. No. 8240 affected its validity.
Ruling
The motion for rehearing and reconsideration is DENIED with FINALITY.
Ratio Decidendi
On whether the question was a privileged question or point of order: The Court held that Rep. Arroyo's question, "What is that, Mr. Speaker?", was neither a privileged question nor a point of order. A question of privilege affects the duties, conduct, rights, privileges, dignity, integrity, or reputation of the House or its members. A point of order is used to require observance of the House's rules and parliamentary procedure. Rep. Arroyo's query was a simple request for clarification, not falling under these definitions. On whether the Chair ignored Rep. Arroyo: The Court found that Rep. Arroyo was not ignored but was simply not heard because he had not first obtained recognition from the Chair. He stood up and spoke without first rising and respectfully addressing the Chair as required by the Rules of the House of Representatives. Consequently, the Chair did not hear him and proceeded to ask for objections to the Majority Leader's motion. On the procedure for approving the conference committee report: The Court reiterated that the practice of asking for objections to the approval of a conference committee report, instead of individual votes, is well-established and considered substantial compliance with the rules. This practice has been accepted and followed in the House of Representatives, as explained by then Majority Leader Arturo M. Tolentino, and is as much a part of parliamentary law as the formal rules. On the questioning of quorum: The Court clarified that the statement regarding the repeated questioning of quorum was made in the context of the specific case where Rep. Arroyo questioned the quorum, a roll call confirmed it, and he announced he would question it again, apparently to delay the voting. The ruling was that the question of quorum cannot be raised repeatedly solely for the purpose of delaying the business of the House when a quorum is obviously present. On the validity of R.A. No. 8240 despite alleged procedural disregard: The Court held that even if the alleged disregard of internal House rules were true, it would not affect the validity of R.A. No. 8240. This is because the rules allegedly violated were internal rules of procedure of the House, not constitutional requirements for the enactment of laws. It is a well-settled principle that a legislative act will not be declared invalid for non-compliance with internal rules.
Main Doctrine
The Court denied the motion for rehearing and reconsideration, holding that the approval of the conference committee report was not railroaded and that the alleged disregard of internal House rules did not affect the validity of the law enacted.