TOPIC: The Enrolled Bill Theory - a principle of judicial interpretation of rules of procedure in legislative bodies.

Under the doctrine,
once a bill passes a legislative body and is signed into law, the courts assume that all rules of procedure in the enactment process were properly followed. That is, "[i]f a legislative document is authenticated in regular form by the appropriate officials, the court treats that document as properly adopted. (Taken from Wiki, as cited from United States v. Thomas)

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Enrolled bill rule provides that if a legislative document is authenticated in regular form by the appropriate officials, the courts treat that document as properly adopted. (Taken from http://definitions.uslegal.com/e/enrolled-bill-rule/)

CASCO PHILIPPINE CHEMICAL Co., Inc. vs. GIMENEZ (1963) Ponente: Concepcion, J. This is a petition for review of a decision of the Auditor General denying a claim for refund of petitioner Casco Philippine Chemical Co., Inc. FACTS: - July 1, 1959: Pursuant to RA 2609, otherwise known as the Foreign Exchange Margin Fee Law, the Central Bank issued Circular No. 95 which fixed a uniform margin fee of 25 % on foreign exchange transactions. - Several times in Nov and Dec 1959, petitioner Casco – which is engaged in the manufacture of synthetic resin glues – bought foreign exchange for the importation of urea and formaldehyde – which are the main raw materials in the production of said glues – and paid a margin fee aggregating Php33,765.42 - In May 1960, Casco made another purchase of foreign exchange and paid the sum of Php6,345.72 as margin fee. - Relying upon Resolution No. 1529 of the Monetary Board of the Central Bank, petitioner had sought the refund of the first margin fee, and soon after, requested for the second. - The CB issued the corresponding margin fee vouchers for the refunds BUT the Auditor of the Bank refused to pass audit and approve said vouchers, on the ground that the exemption granted by the Monetary Board for separate importations of urea and formaldehyde is not in accord with the provisions of section 2, paragraph XVIII of RA 2609. ISSUE: WON “urea” and “formaldehyde” are exempt by law from the payment of the said margin fee. ARGUMENTS/RULING/RATIO: - Petitioner: The term “urea formaldehyde”, which, according to the abovementioned provision of RA 2609, is exempted, should be construed as “urea” AND “formaldehyde”. - SC: As concluded from the statement of the Commissioner of the National Institute of Science and Technology, “urea formaldehyde” is clearly a finished product, which is patently distinct and different from “urea” and “formaldehyde”. Petitioner: The bill approved in Congress contained the copulative conjunction “and” between the terms “urea” and “formaldehyde”, and the members of Congress intended to exempt the said chemicals. To support this view, Casco cited the statements made on the floor of the Senate. SC: Said individual statements do not reflect the view of the Senate, much less the intent of the House. Furthermore, it is settled that the enrolled bill – which uses the term “urea formaldehyde” instead of “urea and formaldehyde” – is conclusive upon the courts as regards the tenor of the measure passed by Congress and approved by the President.

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JUDGEMENT: Decision affirmed. not by judicial decree. .- If there has been any mistake in the printing of the bill before it was certified by Congress and approved by the Executive – on which we cannot speculate. without jeopardizing the principle of separation of powers – the remedy is by amendment or curative legislation.

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