G.R. No. L-23475. April 30, 1974.
HERMINIO A. ASTORGA, in his capacity as Vice-Mayor of Manila, petitioner, vs. ANTONIO J. VILLEGAS, in his capacity as Mayor of Manila, et al., respondents.

FACTS

House Bill No. 9266, a bill of local application, was passed by the House of Representatives and sent to the Senate. During Senate deliberations on second reading, substantial amendments were introduced by Senator Arturo Tolentino and approved. However, the Secretary of the Senate erroneously certified to the House a different, minor amendment proposed by Senator Gerardo Roxas, which had not been formally approved. The House, unaware of the discrepancy, approved this certified version. The enrolled bill, containing the Roxas amendment and not the Tolentino amendments, was then signed by the presiding officers of both Houses and subsequently approved by the President, becoming Republic Act No. 4065 . Upon discovery of the error, the Senate President informed the President that his signature on the enrolled bill was invalid as it did not reflect the bill actually passed. The President then withdrew his approval. Respondent Mayor Villegas, relying on these events, issued orders to disregard R.A. No. 4065 .

ISSUE

Whether Republic Act No. 4065 , as signed by the President, is a valid law despite a discrepancy between the bill actually passed by the Senate and the text of the enrolled bill presented for executive approval.

RULING

The Supreme Court ruled that R.A. No. 4065 is not a valid law. The Court abandoned a strict application of the enrolled bill doctrine, which presumes that an enrolled bill is conclusive of its due enactment. While acknowledging the general respect accorded to an enrolled bill, the Court held that this presumption is not absolute and may be rebutted by clear, official records from the legislative journal itself. In this specific case, the Senate journal indisputably showed that substantial amendments (the Tolentino amendments) were approved on the floor, yet these were entirely omitted from the final enrolled version signed into law. The Court emphasized it was not being asked to correct or insert these amendments, but to declare that the bill presented to the President was not the one Congress passed. Since the text approved by the executive was not the text approved by the Senate, no law was validly enacted. The rectification by the Senate President and the withdrawal of approval by the Chief Executive were given effect to prevent the perpetuation of a manifest error and mischievous consequences not intended by the legislature. The petition was denied and R.A. No. 4065 was declared not to have been duly enacted.