LABAY, Eurica Jane M.

JD 1-5

Arroyo vs De Venecia (1997)

G.R. No. 127255 | 1997-08-14

Facts: The present petition challenges the validity of Republic Act No. 8240, which amends
certain provisions of the National Internal Revenue Code (NIRC) by imposing so-called "sin
taxes" (actually specific taxes) on the manufacture and sale of beer and cigarettes. The law
originated in the House of Representatives as H. No. 7198. This bill was approved on third
reading and transmitted to the Senate which approved it with certain amendments on third
reading. A bicameral conference committee was formed to reconcile the disagreeing provisions
of the House and Senate versions of the bill. Rep. Joker Arroyo registered to interpellate. In the
course of his interpellation, Rep. Arroyo announced that he was going to raise a question on the
quorum, although until the end of his interpellation he never did. On the same day, the bill was
signed by the Speaker of the House of Representatives and the President of the Senate and
certified by the respective secretaries of both Houses of Congress as having been finally passed
by the House of Representatives and by the Senate on November 21, 1996. The enrolled bill was
signed into law by President Fidel V. Ramos on November 22, 1996. Petitioners, as members of
the House of Representatives, brought this suit against respondents Jose de Venecia, Speaker of
the House of Representatives, Deputy Speaker Raul Daza, among others, charging violation of
the rules of the House which petitioners claim are "constitutionally mandated." Consequently,
violation of the House rules is a violation of the Constitution itself. Petitioners also charge that
the session was hastily adjourned at 3:40 p.m. on November 21, 1996 and the bill certified by
Speaker Jose De Venecia to prevent petitioner Rep. Arroyo from formally challenging the
existence of a quorum and asking for a reconsideration.
Issue: Whether or not the House of Reps committed a grave abuse of discretion in enacting RA
8240.

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, Sections 26-27. Petitioners
do not claim that there was no quorum but only that, by some maneuver allegedly in violation of
the rules of the House, Rep. Arroyo was effectively prevented from questioning the presence of a
quorum.

The Constitution declares that each house shall determine the rules of its own proceedings and
shall have all powers necessary for a branch of the Legislature of a free and independent state.
Rules of proceedings are the servants of the House and subject to its authority. This authority
may be abused, but when the House has acted in a matter clearly within its power, it would be an
unwarranted invasion of the independence of the legislative department for the court to set aside
such action as void because it may think that the House has misconstrued or departed from its
own rules of procedure.