Astroga v.

Villegas, 56 SCRA 714 (1974)

FACTS: House Bill No. 9266, which became Republic Act 4065, was a bill of local application
that defined the powers, rights and duties of the Vice-Mayor of Manila. The bill was passed
by the House of Representatives without amendments and sent to the Senate for
concurrence. The Senate Committee on Provinces and Municipal Governments and Cities
recommended a minor amendment, but on the floor of the Senate, substantial amendments
were introduced by Senator Tolentino and approved by the Senate. However, the enrolled
bill that was sent to the President for approval did not contain the Tolentino amendments,
but only the committee amendment. The President signed the bill into law as Republic Act
4065. Senator Tolentino issued a press statement that the enrolled bill was a wrong version
of the bill actually passed by the Senate. The President then withdrew his signature and
returned the bill to the Senate. Mayor Villegas of Manila refused to comply with the
provisions of Republic Act 4065, claiming that it never became law. Vice-Mayor Astorga filed
a petition for mandamus, injunction and/or prohibition to compel the respondents to comply
with the law.

ISSUES: Whether or not Republic Act 4065 became a valid law despite the discrepancy
between the enrolled bill and the journal of the Senate.

HELD: The Supreme Court dismissed the petition and held that Republic Act 4065 did not
become a valid law. The Court applied the journal entry rule, which states that in case of
conflict between the enrolled bill and the journal, the latter prevails. The Court reasoned
that the journal is the official record of the proceedings of the legislature, and that the
enrolled bill is only one of the steps in the legislative process. The Court also cited the
constitutional provision that requires the yeas and nays of the members of each house on
the final passage of every bill to be entered in the journal. The Court said that this provision
implies that the journal has higher evidentiary value than the enrolled bill. The Court also
noted that the discrepancy was not a mere clerical error, but a substantial change that
affected the rights and duties of the Vice-Mayor of Manila.

NOTES:

 Republic Act No. 4065 entitled "AN ACT DEFINING THE POWERS, RIGHTS AND
DUTIES OF THE VICE-MAYOR OF THE CITY OF MANILA, FURTHER AMENDING FOR
THE PURPOSE SECTIONS TEN AND ELEVEN OF REPUBLIC ACT NUMBERED FOUR
HUNDRED NINE, AS AMENDED, OTHERWISE KNOWN AS THE REVISED CHARTER OF
THE CITY OF MANILA"

 Enrolled bill theory is based mainly on "the respect due to coequal and independent
departments," which requires the judicial department "to accept, as having passed
Congress, all bills authenticated in the manner stated."
 If the attestation is absent and the same is not required for the validity of a statute ,
the courts may resort to the journals and other records of Congress for proof of its
due enactment.

 The (1935) Constitution is silent as to what shall constitute proof of due enactment
of a bill. It does not require the presiding officers to certify to the same. But the said
Constitution does contain the following provisions:

I. Sec. 10 (4). "Each House shall keep a Journal of its proceedings, and from time
to time publish the same, excepting such parts as may in its judgment require
secrecy; and the yeas and nays on any question shall, at the request of one-fifth
of the Members present, be entered in the Journal."

II. Sec. 21 (2). "No bill shall be passed by either House unless it shall have been
printed and copies thereof in its final form furnished its Members at least three
calendar days prior to its passage, except when the President shall have certified
to the necessity of its immediate enactment. Upon the last reading of a bill no
amendment thereof shall be allowed, and the question upon its passage shall be
taken immediately thereafter, and the yeas and nays entered on the Journal."

 The case is an example of the application of the journal entry rule, which is a rule of
statutory construction that gives preference to the journal over the enrolled bill in
case of conflict. The rule is based on the principle that the journal is the best
evidence of the legislative intent and the true history of a bill.

 The case also shows the difference between a bill of local application and a bill of
general application. A bill of local application is one that affects only a particular
political subdivision, such as a city or a province. A bill of general application is one
that applies to the entire nation or to a class of persons or things. A bill of local
application requires only a majority vote of the members present in each house,
while a bill of general application requires a majority vote of all the members of each
house.