ARROYO VS.

DE VENECIA
G.R. No. 127255. August 14, 1997
Facts:
Petitioners filed for a petition for certiorari and/or prohibition challenging the
validity of Republic Act No. 8240, which amends certain provisions of the
National Internal Revenue Code by imposing so-called sin taxes (actually specific
taxes) on the manufacture and sale of beer and cigarettes.
The bicameral conference committee submitted its report to the House of
Representatives. The Chair (Deputy Speaker Raul Daza) declared the presence of
a quorum which was appealed by Rep. Arroyo, but his motion was defeated
when put to a vote.
The interpellation of the sponsor proceeded and the bill was approved on its
third reading.
Petitioners claim that the passage of the law in the House was railroaded. They
claim that Rep. Arroyo was still making a query to the Chair when the latter
declared Rep. Albanos motion approved.
Issue:
Whether or not R.A. No. 8240 is null and void because it was passed in violation of
the rules of the House, thus, s a violation of the Constitution itself?
Held:
What was alleged to have been violated in the enactment of R.A. No. 8240 are
merely internal rules of procedure of the House rather than constitutional
requirements for the enactment of a law, i.e., Art. VI, 26-27. In this case, no rights of
private individuals are involved but only those of a member who, instead of seeking
redress in the House, chose to transfer the dispute to this Court. We have no more
power to look into the internal proceedings of a House than members of that House
have to look over our shoulders, as long as no violation of constitutional provisions
is shown.
It would be an unwarranted invasion of the prerogative of a coequal department for
this Court either to set aside a legislative action as void because the Court thinks
the House has disregarded its own rules of procedure, or to allow those defeated in
the political arena to seek a rematch in the judicial forum when petitioners can find
their remedy in that department itself. It would be acting in excess of its power and
would itself be guilty of grave abuse of its discretion were it to do so. Petitioners can
seek the enactment of a new law or the repeal or amendment of R.A. No. 8240. In
the absence of anything to the contrary, the Court must assume that Congress or
any House thereof acted in the good faith belief that its conduct was permitted by
its rules, and deference rather than disrespect is due the judgment of that body.
The petition for certiorari and prohibition was dismissed.