JOKER P. ARROYO ET.AL. v. JOSE DE VENECIA ET AL.

G.R. No. 127255, August 14, 1997, MENDOZA, J.

At any rate, courts have declared that 'the rules adopted by deliberative bodies are subject to revocation, modification or
waiver at the pleasure of the body adopting them.' And it has been said that 'Parliamentary rules are merely procedural, and with
their observance, the courts have no concern. They may be waived or disregarded by the legislative body.' Consequently, 'mere
failure to conform to parliamentary usage will not invalidate the action (taken by a deliberative body) when the requisite number
of members have agreed to a particular measure.'

Facts:

Arroyo questioned the validity of RA No. 8240 which amends certain provisions of NIRC imposing sin taxes on
manufacture and sale of beer and cigarettes. He alleged that law was passed in violation of Internal House Rules. Arroyo
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. He filed a petition for certiorari and prohibition
before the SC. Jose De Venecia on his defense is anchored on the principle of separation of powers and the enrolled bill
doctrine. He argued that the Court is not the proper forum for the enforcement of the rules of the House and that there is no
justification for reconsidering the enrolled bill doctrine. Although the Constitution provides in Art. VI, §16(3) for the adoption
by each House of its rules of proceedings, enforcement of the rules cannot be sought in the courts except insofar as they
implement constitutional requirements such as that relating to three readings on separate days before a bill may be passed.

Issue:

Whether or not the Courts may enforce Internal House Rules

Ruling:

No, It is clear from the foregoing facts that what is 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.

Arroyo 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. To begin with, this contention
stands the principle on its head. In the decided cases, the constitutional provision that "each House may determine the rules of
its proceedings" 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. Here petitioners cite the provision for the opposite purpose of
invoking judicial review.

But the cases, both here and abroad, in varying forms of expression, 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, in the absence of showing that there
was a violation of a constitutional provision or the rights of private individuals.

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. SC has 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.
Arroyo must realize that each of the three departments of our government has its separate sphere which the others may not
invade without upsetting the delicate balance on which our constitutional order rests. Due regard for the working of our
system of government, more than mere comity, compels reluctance on our part to enter upon an inquiry into an alleged
violation of the rules of the House.