FACTS:

This case involves a petition challenging the validity of Republic Act No. 8240, which imposed "sin taxes" on the manufacture and sale of beer and cigarettes. The petitioners, who are members of the House of Representatives, argue that the law was not properly passed because the House Chair violated several internal rules of procedure. They claim that the Chair did not call for the yeas or nays, ignored a question raised, refused to recognize another question, and suspended the session without ruling on a motion. The session was hastily adjourned and the bill was certified to prevent a petitioner from challenging the quorum. The petitioners ask the court to reexamine the enrolled bill doctrine and exercise its power to review claims of grave abuse of discretion. The respondents defend the validity of the law, arguing that internal rules are not judicially enforceable unless they violate constitutional requirements. The court finds no grounds to hold that Congress committed a grave abuse of discretion and dismisses the case. The court notes that alleged violations of internal rules are not constitutional requirements for law enactment and that courts cannot inquire into such violations unless they violate a constitutional provision or the rights of private individuals. The court cites precedents to establish the principle that each house of the legislature has the power to determine its own rules of proceedings, and failure to properly consider a law, even if it violates internal rules, does not render the law invalid.

ISSUES:

1. Whether the court can declare an act of the legislature void for non-compliance with the rules of procedure made by itself.

2. Whether the court can review an alleged violation of the rules of the House.

3. Whether the passage of the law in the House was "railroaded" and whether there was a violation of the rules of the House.

4. Whether the petitioners were prevented from seeking reconsideration as a result of the precipitate suspension and subsequent adjournment of the session.

5. Whether the signing of the bill by the Speaker of the House and the President of the Senate and the certification by the secretaries of both Houses of Congress that it was passed on November 21, 1996 is conclusive of its due enactment.

6. Whether the question of quorum raised by Rep. Arroyo was effectively prevented and if so, whether it constitutes a grave abuse of discretion.

7. Whether the enrolled bill rule should be applied in determining the validity of Republic Act No. 8240.

8. Whether there is evidence to prove the due enactment of the law.

RULING:

1. The court cannot declare an act of the legislature void for non-compliance with its own rules of procedure.

2. The court cannot review an alleged violation of the rules of the House, as long as no violation of constitutional provisions is shown.

3. The method used in approving the conference committee report is not contrary to the rules of the House. No specific rule requires the Chair to restate the motion and conduct a viva voce or nominal voting for the approval of a conference committee report. The manner of approval used in this case has basis in legislative practice, and it has been consistently used in previous cases. The practice of approving conference committee reports without further voting after calling for objections has been recognized and accepted. The court cannot provide a second opinion on the best procedure, and it is not a matter for judicial consideration. The Constitution does not require the yeas and the nays of the Members to be taken in every vote, except in specific instances mentioned in the Constitution.

4. The petitioners were not prevented from seeking reconsideration. The session was suspended to allow the parties to settle the problem, and when it resumed, the petitioner did not say anything. The fact that no objection was made when the Majority Leader moved for adjournment until the following week indicates that there was no intention to seek reconsideration. It was the petitioners' choice not to submit proper motions for the House to act upon.

5. The signing of the bill and the certification by the secretaries of both Houses of Congress that it was duly passed on November 21, 1996 are conclusive of its due enactment. The enrolled bill doctrine states that once a bill is signed by the presiding officers and certified as passed, it is considered as valid and binding unless there is evidence to the contrary. In this case, there is no evidence to dispute the certification, and therefore the enrolled bill is accorded respect.

6. The question of quorum raised by Rep. Arroyo was effectively prevented, and it does not constitute a grave abuse of discretion. The Court held that it is a matter of internal procedure of the House, with which the Court should not be concerned. Rep. Arroyo's previous motion to adjourn for lack of quorum had already been defeated, and the roll call established the existence of a quorum. Rep. Arroyo waived his objection by continuing his interpellation, thereby acknowledging the presence of a quorum.

7. Yes, the enrolled bill rule should be applied. The Supreme Court stated that the enrolled bill rule is the prevailing doctrine in determining the validity of a law and has been cited with approval by text writers both in the Philippines and abroad. This rule states that a duly authenticated law carries a solemn assurance by the legislative and executive departments of the government that it was passed by Congress. Thus, the Court must act upon that assurance and accept the law as having been passed by Congress. Should the question of constitutionality arise, the Court can determine its conformity with the Constitution. The Court found no reason to depart from this rule, as the petitioners did not present any argument justifying such a departure.

8. Yes, there is evidence to prove the due enactment of the law. The Journal of the House of Representatives on November 21, 1996, shows that the conference committee report on House Bill No. 7198, which became Republic Act No. 8240, was approved on that day. The Constitution requires each House to keep a Journal of its proceedings. The Journal is regarded as conclusive with respect to matters required by the Constitution to be recorded therein. In the absence of evidence to the contrary, the Journals are also accorded conclusive effect. Thus, since the bill is shown in the Journal, its due enactment has been duly proven.

PRINCIPLES:

• Courts cannot declare an act of the legislature void for non-compliance with rules of procedure made by itself.

• Rules of procedure made by the legislature are subject to revocation, modification, or waiver by the legislative body.

• Mere failure to conform to the rules of procedure does not nullify an act if the requisite number of members have agreed to the measure.

• The court cannot review alleged violations of the rules of the House unless private rights are involved or there is a violation of constitutional provisions.

• Each branch of government has its separate sphere which the others may not invade without upsetting the delicate balance of constitutional order.

• The court's function is to check whether a government branch or agency has gone beyond the constitutional limits of its jurisdiction, but not to correct apparent errors or differences in views.

• The approval of a conference committee report without further voting after calling for objections is an accepted legislative practice.

• The court cannot provide a second opinion on the best procedure for approval of laws since it is a matter for the legislative branch to manage its own affairs.

• The Constitution does not require the yeas and the nays of the Members to be taken in every vote, except in specific instances mentioned in the Constitution.

• Petitioners must exercise their right to seek reconsideration within the prescribed rules and procedures of the legislative body.

• Enrolled Bill Doctrine - Once a bill is signed by the presiding officers and certified as passed, it is considered as valid and binding, unless there is evidence to the contrary.

• Respect for the Separation of Powers - The Court should not interfere with matters of internal procedure of the legislative branch unless there is a clear violation of constitutional provisions.

• Enrolled bill rule: A duly authenticated law carries a solemn assurance by the legislative and executive departments of the government that it was passed by Congress. The rule requires the Court to act upon that assurance and accept the law as having been passed by Congress, leaving the court to determine its conformity with the Constitution.

• Conclusive effect of the Journal: The Journal of each House is required by the Constitution to record its proceedings. The Journal is regarded as conclusive with respect to matters required by the Constitution to be recorded therein. In the absence of evidence to the contrary, the Journals are also accorded conclusive effect.

• Deference to the judgment of Congress: The Court must assume that Congress or any House thereof acted in good faith belief that its conduct was permitted by its rules. Therefore, deference rather than disrespect is due to the judgment of the legislative body. The Court should not set aside a legislative action as void based on its own perception of legislative skullduggery.