G.R. No. 127255.

June 26, 1998

Arroyo v De Venecia

Facts:
The petitioners are challenging the validity of R.A. 8420 (amends certain provisions of the
National Internal Revenue Code by imposing “Sin Taxes”) by filing a petition for for certiorari and/or
prohibition. They claim that respondents violated the rules of the House which are "constitutionally
mandated" so that their violation is tantamount to a violation of the Constitution when the Chair of the
Committee (Deputy Speaker Raul Daza) allegedly ignored a privileged question raised by Rep. Arroyo
during the committee report for the approval of R.A. 8420.
Petitioners claim that there are actually four different versions of the transcript of this portion of
Rep. Arroyo's interpellation:
(1)the transcript of audio-sound recording of the proceedings in the session hall
(2) the transcript of the proceedings from 3:00 p.m. to 3:40 p.m. of November 21, 1996, as certified by
the Chief of the Transcription Division on November 21, 1996
(3) the transcript of the proceedings from 3:00 p.m. to 3:40 p.m. of November 21, 1996 as certified by
the Chief of the Transcription Division on November 28, 1996
(4) the published version
Petitioners contend that the House rules were adopted pursuant to the constitutional provision
that "each House may determine the rules of its proceedings" and that for this reason they are judicially
enforceable. This contention was invoked by parties, although not successfully, precisely to support
claims of autonomy of the legislative branch to conduct its business free from interference by courts. In
this case, petitioners cite the provision for the opposite purpose of invoking judicial review.

Issue:
Whether or not the House of Representatives acted with grave abuse of discretion in enacting R.A. No.
8240 affects its validity?

Held:
The petition was dismissed. According to the findings of the court, the alleged violations are merely
internal rules of procedures rather than what petitioners claim to be constitutional requirements for
enacting laws. 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. 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.