Astorga v.

Villegas
Case No. 23
G.R. No. L-23475 (April 30, 1974)
Chapter I, Page 11, Footnote No.37

FACTS:
House Bill No. 9266 was passed from the House of Representatives to the Senate. Senator Arturo Tolentino
made substantial amendments which were approved by the Senate. The House, without notice of said amendments,
thereafter signed its approval until all the presiding officers of both houses certified and attested to the bill. The
President also signed it and thereupon became RA 4065. Senator Tolentino made a press statement that the enrolled
copy of House Bill No. 9266 was a wrong version of the bill because it did not embody the amendments introduced
by him and approved by the Senate. Both the Senate President and the President withdrew their signatures and
denounced RA 4065 as invalid. Petitioner argued that the authentication of the presiding officers of the Congress is
conclusive proof of a bill’s due enactment.

ISSUE:
W/N House Bill No. 9266 is considered enacted and valid.

HELD:
Since both the Senate President and the Chief Executive withdrew their signatures therein, the court
declared that the bill was not duly enacted and therefore did not become a law.
The Constitution requires that each House shall keep a journal. An importance of having a journal is that in
the absence of attestation or evidence of the bill’s due enactment, the court may resort to the journals of the
Congress to verify such. “Where the journal discloses that substantial amendment were introduced and approved and
were not incorporated in the printed text sent to the President for signature, the court can declare that the bill has not
been duly enacted and did not become a law.”