CASE # 32 Arroyo v.

De Venecia
GR 127255, 277 SCRA 268 [Aug 14, 1997]

Facts: HB 7198 was transmitted by the House of Reps to the Senate and was
thereafter approved with amendments. Upon being sent back to the House of
Reps, Rep. Albano moved to ratify the bicameral conference committee report.
Dep. Speaker Daza approved Albano’s motion after apparently hearing no
objection thereto although petitioner Rep. Arroyo
had in fact stood up and asked “What is that, Mr. Speaker?” at the instant. Notably,
Arroyo did not request to be recognized in accordance to the House Rules. The
Dep. Speaker then called the session adjourned upon
Albano’s motion notwithstanding the pending query of Arroyo. Petitioners aver these
are violative of the Rules of the House and that RA 8240, 87 the law which evolved
from HB 7198, is thereby null and void. Petitioners
contend that the Rules embody the “constitutional mandate” in Art. VI sec 16 (3) that
“each House may determine the rules of its proceedings” and that consequently,
violation of House rules is a violation of the Constitution itself.

Issue: Is RA 8240 unconstitutional because it was passed in violation of the Rules

of the House?

Held. No. Arroyo did not have the floor when he just stood up without being
recognized, so as a result, he was not heard. The Court finds no ground for holding
that Congress committed a grave abuse of discretion in enacting
RA 8240. Even assuming arguendo that petitioners’ allegations are true, it is clear
that what is alleged to have been violated in the enactment of RA 8240 are merely
internal rules of procedure of the House rather than
constitutional requirements. Jurisprudence, both here and abroad, all deny to the
courts the power to inquire into allegations that, in enacting a law, a House of
Congress failed to comply with its own rules. A
legislative act will not be declared invalid for noncompliance to such.

Note: Art. VI sec 16 (3) “Each House may determine the rules of its proceedings,
punish its members for disorderly behavior, and, with the concurrence of two-thirds
of all its members, suspend, or expel a member. A penalty of suspecnsion, when
imposed, shall not exceed sixty days.