Arroyo vs De Venecia Digest

Arroyo vs De Venecia

Facts:

An amendment to the National Internal Revenue Code was introduced to the House of Representatives
involving taxations on the manufacture and sale of beer and cigarettes. This was later passed accordingly
and brought to the House of Senate. Upon the interpellation on the second reading, herein petitioner
moved for adjournment for lack of quorum which is constitutionally needed to conduct business.
Petitioner’s motion was defeated and was railroaded. The bill was then signed into law by President Fidel
Ramos.

Issue:

Whether or not the law passed on violation on the constitutional mandate.

Held:

There is no rule of the House concerned that quorum shall be determined by viva voce or nominal voting.
The Constitution does not require that the yeas and nays of the Members be taken every time a House has
to vote, except only on the following instances upon the last and the third readings of the bill, at the
request of 1/5 of the Members present and in passing a bill over the veto of the President. Second, there is
obviousness on the part of the petitioner to delay the business of the House, thus eliminating the alleged
skullduggery on part of the accused. Third, the enrolled bill doctrine states that enrolled bills are in itself
conclusive thus legally binding provided it is in harmony with the constitution. Lastly, the court upheld
principle of separation of powers, which herein, is applicable for the legislative branch for it has exercised
its power without grave abuse of discretion resulting to lack or excess of jurisdiction.

Facts: RA 8240 which amends certain provisions of the National Internal Revenue Code by
imposing so-called ”sin taxes” on the manufacture and sale of beer and cigarettes were
challenged by Representative Joker Arroyo. The bicameral committee after submitting its
report to the House, the chairman of the committee proceeded to deliver his sponsorship
speech and was interpellated. Arroyo also interrupted to move to adjourn for lack of
quorum. His motion was defeated and put to a vote. The interpellation of the sponsor
proceeded and the bill was approved on its third reading.
Issue: Whether or not Arroyo should have been heard for his call to adjourn for lack of
quorum?
Decision: Petition dismissed. It is unwarranted invasion of the prerogative of a coequal
department of the 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 the petitioners can find their
remedy in their own department.