Astorga v. Villegas G.R. No.

L-23475 (April 30, 1974) - Journal Entry Rule

FACTS

-House Bill No. 9266 was passed without amendments from the House of Representatives to the
Senate.
-Senator Roxas made minor amendments.
-On the second reading, Senator Tolentino made substantial amendments which were approved by
the Senate.
-The Senate sent a letter to the House of Representatives that the bill was passed "with
amendments", attaching a certificate of amendment by Sen Roxas and not the Tolentino ones
which were actually approved by the Senate.-The presiding officers of both houses all signed its
approval and sent it to the President for signature. The President also signed it and thereupon
became RA 4065.
-Afterwards, Senator Tolentino made a press statement that the enrolled copy was a wrong version
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.

ISSUE/S

-Astorga argued that the attestation in the bill is not mandatory and would not affect the validity of
the statute, thus RA 4065 would remain valid and binding.
-Villegas argued that the RA 4065 never became law because it was not the bill that was actually
passed by the Senate.
-Should the entries in the journal be consulted? Is the RA 4065 valid?

RULING/S

-The Constitution requires that each House shall keep a journal, which the Court may resort to in
case there is no attestation or evidence of the bill's enactment.
-The journal indeed showed that substantial amendments were introduced and approved but not
incorporated in the printed text sent to the President for signature.
-Thus the court declared that the bill was not duly enacted and therefore did not become law.

EFFECT OF WITHDRAWAL OF AUTHENTICATION

- The Speaker and the President may withdraw their signatures from the signed bill when there is
serious and substantial discrepancy between  the  text  of  the  bill  as  deliberated  and  shown
by  the  journal, and that of the enrolled bill.
-This renders the bill without attestation and nullifies its status as an enrolled bill.
In this case, the bill is no longer accorded absolute verity as regards its text and the entries in the
journal should be consulted.