G.R. No. 127255 , August 14, 1997
JOKER P. ARROYO, EDCEL C. LAGMAN, JOHN HENRY R. OSMEÑA, WIGBERTO E. TAÑADA, AND RONALDO B. ZAMORA, PETITIONERS, VS. JOSE DE VENECIA, RAUL DAZA, RODOLFO ALBANO, THE EXECUTIVE SECRETARY, THE SECRETARY OF FINANCE, AND THE COMMISSIONER OF INTERNAL REVENUE, RESPONDENTS.

FACTS

Petitioners, members of the House of Representatives, filed a petition for certiorari and/or prohibition challenging the validity of Republic Act No. 8240 (the “sin tax” law). They alleged that the law was passed in violation of the House’s internal rules during the session of November 21, 1996. The bill (H. No. 7198) was approved on third reading in the House and Senate, and a bicameral conference committee report was submitted. During the House session to consider the report, petitioner Rep. Joker Arroyo was interpellating. Respondent Majority Leader Rodolfo Albano moved for the approval of the conference committee report. The Deputy Speaker (Raul Daza) asked, “Any objection to the motion?” and then immediately declared, “There being none, approved,” despite Rep. Arroyo standing up and stating, “Objection, I stood up, so I wanted to object.” The session was then suspended and later adjourned. Petitioners claimed this procedure violated specific House rules regarding motions, recognition of members, and points of order, effectively preventing Rep. Arroyo from questioning the quorum. They argued these rules are constitutionally mandated under Article VI, Section 16(3), and their violation is tantamount to a constitutional violation. They also challenged the conclusiveness of the enrolled bill doctrine and the Speaker’s certification of the bill’s passage.

ISSUE

Whether the Court can review allegations that the House of Representatives violated its own internal rules of procedure in the enactment of Republic Act No. 8240 , and if such violations would render the law unconstitutional.

RULING

The Supreme Court DISMISSED the petition. It held that alleged violations of the internal rules of procedure of the House of Representatives, in the absence of any showing of a violation of a constitutional requirement or of private rights, are beyond the scope of judicial review. The constitutional grant to each House to “determine the rules of its proceedings” is a grant of autonomy and not a basis for courts to enforce those rules. The Court reaffirmed the enrolled bill doctrine, which holds that an enrolled bill, authenticated by the signatures of the Speaker of the House and the President of the Senate and approved by the President, is conclusive upon the courts as to its due enactment. The journal entry showing the bill’s approval is also binding. The Court found that the approval of the conference committee report by motion was in accordance with established parliamentary practice and that the actions taken by the presiding officer were within his discretionary powers to control the proceedings. No grave abuse of discretion was committed by Congress in the passage of R.A. No. 8240 .