Arroyo v.

De Venecia

Facts: An amendment to the National Internal Revenue Code was introduced to the House of
Representatives involving taxations on the manufacture and sale of beer and cigarettes. This was
later passed accordingly and brought to the House of Senate. Upon the interpellation on the
second reading, herein petitioner moved for adjournment for lack of quorum which is
constitutionally needed to conduct business. Petitioner’s motion was defeated and was
railroaded. The bill was then signed into law by President Fidel Ramos.

Issue: Whether or not the law was passed on violation on the constitutional mandate.

Held: There is no rule of the House concerned that quorum shall be determined by viva voce or
nominal voting. The Constitution does not require that the yeas and nays of the Members be
taken every time a House has to vote, except only on the following instances – upon the last and
the third readings of the bill, at the request of 1/5 of the Members present and in repassing a bill
over the veto of the President. Second, there is obviousness on the part of the petitioner to delay
the business of the House, thus eliminating the alleged skullduggery on part of the accused.
Third, the enrolled bill doctrine states that enrolled bills are in itself conclusive thus legally
binding provided it is in harmony with the constitution. Lastly, the court upheld principle of
separation of powers, which herein, is applicable for the legislative branch for it has exercised its
power without grave abuse of discretion resulting to lack or excess of jurisdiction.