Arroyo, et al. vs.

De Venecia
Facts:
In the case at bar, the validity of R.A. 8240 or H. o. !"#8 is bein$ %&estioned by 'etitioners
based on several $ro&nds. (hey ar$&e that:
") *+rinci'al ar$&,ent) R.A. 8240 is n&ll and void beca&se it -as 'assed in violation of the
r&les of the Ho&se. -hich e,body the constit&tional ,andate thereby violatin$ the
/onstit&tion itself. (herefore, RA 8240 is &nconstit&tional and sho&ld be considered void.
2) (hese s'ecific r&le violations -ere:
a. (he /hair, in s&b,ittin$ the conference co,,ittee re'ort to the Ho&se, did not
call for yeas or nays *-hich sho&ld be doc&,ented accordin$ to the r&les) b&t
si,'ly as0ed for a''roval by ,otion in order to 'revent 'etitioner Arroyo fro,
%&estionin$ the 'resence of a %&or&,. *R&le VIII 1 23, R&le 4VII 1 "02)
b. (he fact that the /hair deliberately i$nored Re'. Arroyo5s %&estion and did not
re'eat Albano5s ,otion to a''rove or ratify violated R&le 4I4 1 ""2 *see transcri't)
c. (he /hair, in ref&sin$ to reco$ni6e Arroyo and 'roceedin$ to act on Albano5s
,otion, violated R&le 4VI 1 #!
d. (he /hair violated R&le 44 11"2"7"22, R&le 44I 1 "22, and R&le 4VIII 1 "0# in
s&s'endin$ the session -itho&t first r&lin$ on Re'. Arroyo5s %&estion, -hich is a
'oint of order accordin$ to the r&les.
(he 'etitioners herein re%&ests the /o&rt to ascertain the above alle$ations challen$in$ the
constit&tionality of the act.
Iss&es:
") 89 the violations of the r&les of the Ho&se *if any) constit&te a violation of the
/onstit&tion itself: *8hich is si$nificant beca&se if not, the /o&rt -o&ld lose its
;&risdiction)
2) 89 the violation of the r&les of the Ho&se -o&ld n&llify the RA
Held:
") (he alle$ed violations of the R&les of the Ho&se are ,erely internal r&les of 'roced&re rather
than constit&tional re%&ire,ents for the enact,ent of la-s. In these cases, both here and abroad,
deny to the courts the power to inquire into alle$ations that, in enactin$ a la-, a Ho&se of
/on$ress failed to co,'ly -ith its own r&les in the absence of showing that there was a
violation of a constitutional provision.
1ince the r&les violated -ere the r&les that the Ho&se itself created, the /o&rts have no concern
-ith their observance. (he r&les are s&b;ect to the ,odification, revocation or -aiver at the
'leas&re of the body ado'tin$ the,. (he co&rt has no ,ore 'o-er to loo0 into internal
'roceedin$s of the Ho&se as lon$ as no violation of constit&tional 'rovisions *-hether 'roced&ral
or s&bstantial 're;&dicial to 'rivate individ&als) is sho-n.
2) <&otin$ for,er /hief =&stice Fernando:
>?the ,ere fail&re to confor, to the, @internal 'roced&ral r&les established by the bodyA does
not have the effect of n&llifyin$ the act ta0en if the re%&isite n&,ber of ,e,bers have a$reed to a
'artic&lar ,eas&reB
1ide Iss&es:
2a) (he /onstit&tion does not re%&ire that the yeas and nays of the Ce,bers be ta0en every ti,e
the Ho&se has to vote eDce't only in the follo-in$ instances: &'on the last and third readin$s of a
bill, at the re%&est of one7fifth of the Ce,bers 'resent, and in re'assin$ a bill over the veto of the
+resident. 1ince the sit&ation does not fall a,on$ the eDce'tions, 'l&s the fact that the votes of
the Ce,bers by yeas and nays had already been ta0en, they -o&ld no lon$er have to ta0e it
a$ain. No violation of the rules
2b) (he /hair, in a''rovin$ the conference co,,ittee re'ort, and Re' Arroyo, in ob;ectin$ to the
,otion, s'o0e si,&ltaneo&sly. (h&s the a''roval of the ,otion had already been done,
sy,boli6ed by the ban$in$ of the $avel. No violation of the rule
2c E 2d) (he session -as s&s'ended for 2# ,in&tes to allo- the 'arties to settle the 'roble,.
8hen it res&,ed at 2:40', Re' Arroyo did not ob;ect any,ore, si$nifyin$ that a settle,ent has
been ,ade. No violation of the rule
(ranscri't:
CR. AFGAH: Cr. 1'ea0er, I ,ove that -e no- a''rove and ratify the conference co,,ittee re'ort.
(HI DI+J(K 1+IALIR *Cr. Da6a): Any ob;ection to the ,otion:
CR. ARRHKH: 8hat is that, Cr. 1'ea0er:
(HI DI+J(K 1+IALIR: (here bein$ none, a''roved.
*Mavel)
CR. ARRHKH: o, no, no -ait a ,in&te, Cr. 1'ea0er, I stood &'. I -ant to 0no- -hat is the %&estion that the /hair as0ed
the distin$&ished s'onsor.
(HI DI+J(K 1+IALIR: (here -as a ,otion by the Ca;ority Feader for the a''roval of the re'ort, and the /hair called
for ,otion.
CR. ARRHKH: Hb;ection, I stood &', so I -anted to ob;ect.
(HI DI+J(K 1+IALIR: (he session is s&s'ended for one ,in&te.
*I( 8A1 2:0" +.C.)
*2:40 +.C., (HI 1I11IH 8A1 RI1JCID)
(HI DI+J(K 1+IALIR: (he session is res&,ed.
CR. AFGAH: Cr. 1'ea0er, I ,ove to ad;o&rn &ntil fo&r o5cloc0, 8ednesday, neDt -ee0.
(HI DI+J(K 1+IALIR: (he session is ad;o&rned &ntil fo&r o5cloc0, 8ednesday, neDt -ee0.
*I( 8A1 2:40+.C.)
That minute sure went by fast didnt it?