Facts:

- RA 8240 was an enrolled bill. During the conference committee in which both houses of
congress were present, Rep. Arroyo moved to adjourn said conference on the ground that there
was a lack of quorum.
- The speaker of the house, after a roll call, determined there was a quorum. On the same day,
the bill was signed by the Speaker of the House of Representatives and the President of the
Senate and certified by the respective secretaries of both Houses of Congress as having been
finally passed by the House of Representatives and by the Senate on November 21, 1996.
- The enrolled bill was signed into law by President Fidel V. Ramos on November 22, 1996

Petitioners assert that RA 8240 is unconstitutional as it violated the rules of house prior to it’s
promulgation. They assert that House rules embody a “constitutional mandate” in Art. VI section
16(3) and violation of such rules is a violation of the constitution itself.

Issue: W/N RA 8240 is null and void as it was passed in violation of the rules of the House.

Held:
No.

Ratio:
- Osmeña v. Pendatun, it was held: "At any rate, courts have declared that 'the rules adopted by
deliberative bodies are subject to revocation, modification or waiver at the pleasure of the body
adopting them.' And it has been said that 'Parliamentary rules are merely procedural, and with
their observance, the courts have no concern. They may be waived or disregarded by the
legislative body.' Consequently, 'mere failure to conform to parliamentary usage will not
invalidate the action (taken by a deliberative body) when the requisite number of members have
agreed to a particular measure.'"

- Rules are hardly permanent in character. The prevailing view is that they are subject to
revocation, modification or waiver at the pleasure of the body adopting them as they are primarily
procedural. Courts ordinarily have no concern with their observance. They may be waived or
disregarded by the legislative body. Consequently, mere failure to conform to them does not
have the effect of nullifying the act taken if the requisite number of members have agreed
to a particular measure.