College of Law Saint Mary’s University

Arroyo vs De Venecia
G.R. No. 127255 August 14, 1997
Mendoza, J.:

Facts: This is a petition for certiorari challenging the validity of RA 8242 (Tax
Reform Act) for being passed despite violations of the internal rules of the House
of Representatives (HOR). Petitioners, members of the HOR, brought this suit
against respondents De Venecia (speaker of the House), et al, on the ground that
R.A. No. 8240 is null and void because it was passed in violation of the rules of the
House; that these rules embody the "constitutional mandate" in Art. VI, Section
16(3) that "each House may determine the rules of its proceedings" and that,
consequently, violation of the House rules is a violation of the Constitution itself.
Petitioners alleged that during the proceedings, he was effectively prevented from
questioning the presence of a quorum and that the session was hastily adjourned,
and the bill certified by Speaker De Venecia to prevent petitioner from formally
challenging the existence of a quorum and asking for a reconsideration.
Respondents' defense is anchored on the principle of separation of powers and the
enrolled bill doctrine. They argued that 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/s: Whether or not the Congress committed a grave abuse of discretion in
enacting R.A. No. 8240.
Ruling: NO. 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. We have 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. Petitioners
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

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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. We must accordingly
decline the invitation to exercise our power. It would be an unwarranted invasion
of the prerogative of a coequal department for this Court either to set aside a
legislative action as void because the Court thinks the House has disregarded its
own rules of procedure, or to allow those defeated in the political arena to seek a
rematch in the judicial forum when petitioners can find their remedy in that
department itself. WHEREFORE, the petition for certiorari and prohibition is
DISMISSED.

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