Arroyo vs De Venecia

FACTS
Case is a petition for certiorari and prohibition challenging the validity of RA No. 8240 which amends certain
provisions of the NIRC by imposing so-called sin taxes on the manufacture and sale of beer and cigarettes.

A bicameral conference committee was held on November 21, 1996, regarding House Bill no. 7198. The
bill was signed on the same day by the Speaker of the House and the President of the Senate. It was then
subsequently signed into law by President Fidel V. Ramos on November 22, 1996, titled RA No. 8240.
Petitioner contends that RA No. 8240 is null and void because it was passed in violation of the rules of the
House, which in turn, violates the constitution.

Petitioners charge that:

1. Violation of Rule VIII, section 35 and Rule XVII, section 103 of the Rules of the House, the Chair
did not inquire for contentions but simply asked for the approval of the motion
2. Violation of Rule XIX, section 112, Chair deliberately ignored petitioners question
3. Violation of Rule XVI, section 97, Chair refused to recognize petitioner and instead proceeded to
act on Rep. Albanos motion and afterward declared the report approved
4. Violation of Rule XX, section 121-122, Rule XXI, section 123, and Rule XVIII, section 109, Chair
suspended the session without ruling on petitioners question

ISSUE:
W/N Congress committed grave abuse of discretion by passing RA no. 8240

HELD:
Supreme Court finds no ground for holding that congress committed grave abuse of discretion in
enacting RA 8240. The Court held that there was only a violation of the internal rules of procedure of the
House and not the constitutional requirement for the enactment of law, which is Article VI, Section 26-27 of
the 1987 Constitution, pertaining to the existence of a quorum.

1. Court explained that what was violated was only the House rules, and that petitioners cannot invoke
judicial review for the Court has no power to inquire into the failure of the legislature to follow its
own rules. It can only do so in cases where there was a violation of a constitutional provisions on
the rights of private individuals. [Note: Please see full text for cases cited]

2. Court explained that judicial review may not be invoked for there is no actual controversy
to determine, and that no abuse was committed. Court cannot declare any act of the Legislature
void on account of mere non-compliance of internal House rules.

The phrase grave abuse of discretion amounting to lack or excess of jurisdiction has a settled
meaning in the jurisprudence of procedure. It means capricious and whimsical exercise of
judgement by a tribunal exercising judicial or quasi-judicial power as to amount to lack of power.

3. Petitioners explained that the passage of RA 8340 was rail-roaded, wherein some procedures
were not conducted (i.e nominal voting). Court explained that no rule was cited which
specifically requires that in such cases involving the approval of a conference committee
report, the Chair must restate the motion and conduct voting. Court cannot provide a second
 opinion on how procedures ought to be, nor does the Constitution requires a specific method of
doing so.

4. Enrolled Bill Doctrine as a rule of evidence: Court explained that the signing of House Bill by
the Speaker of the House and President of the Senate and certification by the Secretaries of both
Houses are conclusive that it is due to be enacted. Contestations made the petitioner as to overrule
the doctrine, is to repudiate the massive teaching of our cases and overthrow an established rule
of evidence.

The petition for certiorari and prohibition is dismissed.