ARROYO, ET. AL.

vs DE VENECIA
G.R. No. 127255 August 14, 1997 Ponente: Mendoza, J.
FACTS:
● The petitioners are challenging the validity of R.A. 8420 (amending certain provisions of the
National Internal Revenue Code by imposing “Sin Taxes”) by filing a petition for certiorari
and/or prohibition. They claim that respondents violated the rules of the House which are
“constitutionally mandated” so that their violation is tantamount to a violation of the
Constitution when the Chair of the Committee (Deputy Speaker Raul Daza) allegedly
ignored a privileged question raised by Rep. Arroyo during the committee report for the
approval of R.A. 8420.
● Petitioners claim that there are actually four different versions of the transcript of this
portion of Rep. Arroyo’s interpellation:
1. The transcript of audio-sound recording of the proceedings in the session hall
2. The transcript of the proceedings from 3:00pm to 3:40 pm of Nov. 21, 1996, as certified
by the Chief of the Transcription Division on Nov. 21, 1996
3. The transcript of the proceedings from 3:00pm to 3:40 pm of Nov. 21, 1996, as certified
by the Chief of the Transcription Division on Nov. 28, 1996
4. The published version
● Petitioners contend that the House rules were adopted pursuant to the constitutional
provision that “each House may determine the rules of its proceedings” and that for this
reason, they are judicially enforceable. This was invoked by the parties, although not
successfully, precisely to support of claims of autonomy if the legislative branch to conduct
its business free from interference by courts. Petitioners cite the provision for the opposite
purpose of invoking judicial review.
ISSUE:
● Whether or not the House of Representatives acted with grave abuse of discretion in
enacting R.A. 8420 affecting its validity
HELD:
● The petition was dismissed. According to the findings of the court, the alleged violations are
merely internal rules of procedures rather than what petitioners claim to be constitutional
requirements for enacting laws. No rights of private individuals were involved but only
those of a member who, instead of seeking redress in the House, chose to transfer the
dispute to this Court. 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 violated its own rules of procedure. The Court held that it did not have
jurisdiction.
● The prevailing view is that Rules of Proceedings are subject to revocation, modification, or
waiver at the pleasure of the body adopting them as they are primarily procedural.
● The Court is always denied to interfere on the process of the law-making within the House
of Congress, except when:
1. There was a violation of a constitutional provision
2. Violation of the rights of private individuals