Mabanag v. Vito
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the validity of a joint resolution passed by the Philippine Congress proposing an amendment to the Constitution. The petitioners, including senators and representatives, argue that the resolution was not adopted in accordance with the constitutional requirement of a three-fourths vote of all members in each house, as certain elected members were excluded from voting or their votes were not counted. This exclusion, they contend, rendered the proposed amendment unconstitutional. 2. Procedural History: The case originated with a petition for prohibition filed by members of Congress and political party leaders. They sought to prevent the enforcement of a congressional resolution proposing a constitutional amendment and the subsequent Republic Act No. 73, which called for a plebiscite to ratify this amendment. The respondents, including election officials and government treasurers, defended the validity of the resolution and the Act. The case was heard on the pleadings and a stipulation of facts, leading to the Supreme Court's decision. 3. The Petition: The petitioners invoked the original jurisdiction of the Supreme Court, seeking a writ of prohibition. They argued that the proposed constitutional amendment, as embodied in the joint resolution, was invalid because it failed to secure the constitutionally mandated three-fourths vote of all members of both the Senate and the House of Representatives. Specifically, they contended that the exclusion of certain elected senators and representatives from the voting process, or the failure to count their potential votes, meant the required supermajority was not achieved. They asked the Court to declare the resolution and the subsequent plebiscite law unconstitutional.
Issue(s)
Whether the Court has jurisdiction to review the validity of a congressional resolution proposing an amendment to the Constitution. Whether the Enrolled Bill Rule applies to make the authenticated resolution conclusive as to its due enactment, precluding an inquiry into the legislative journals.
Ruling
The petition is dismissed. The Court held that the proposal and ratification of constitutional amendments are political questions, not justiciable. The enrolled bill rule, which accords conclusiveness to authenticated legislative enactments, is binding on the courts out of respect for the co-equal branches of government. Therefore, the Court declined to inquire into the internal proceedings of Congress regarding the vote count for the proposed amendment.
Ratio Decidendi
On Issue 1: The Supreme Court held that the proposal to amend the Constitution is a highly political function performed by Congress in its sovereign legislative capacity. Relying on the United States (US) Supreme Court case of Coleman v. Miller, the Court ruled that the efficacy of the amendatory process is a political question and thus non-justiciable. The Court reasoned that there is no logic in attaching a political character to the ratification phase while withholding it from the proposal phase, as both complement each other in a single scheme. Because the power is committed to the political departments by the Constitution, judicial inquiry would trammel the exercise of the sovereign right of the people to change their fundamental law. The Court concluded that it must respect the decisions of the political branches in matters that the Constitution has placed within their exclusive province. On Issue 2: The Court adopted the Enrolled Bill Rule, asserting that a duly authenticated bill or resolution imports absolute verity and is binding on the courts. The Court cited Section 313 of the Code of Civil Procedure, which provides that a copy signed by the presiding officers is conclusive proof of the due enactment of a law. The Court reasoned that allowing the judiciary to go behind an enrolled bill to examine legislative journals would lead to 'endless confusion' and unsettle the stability of all written laws. It was emphasized that the rule is born of the respect that the judiciary accords to co-equal, coordinate, and independent departments of government. The Court further noted that legislative journals are often unreliable and unauthenticated, making the authenticated enrollment a more secure standard of veracity. Ultimately, the Court refused to check the 'misdoings' of the legislature at the cost of violating established legal principles regarding the finality of authenticated legislative acts.
Main Doctrine
The proposal and ratification of constitutional amendments are political questions, not subject to judicial review, and the enrolled bill rule, which presumes the regularity of legislative enactments, is binding on the courts.