Arroyo vs De Venecia (Topic: Separation of Powers)

G.R. No. 127255 August 14, 1997

Mendoza, J.:

Facts:
This is a petition for certiorari challenging the validity of RA 8242 (Tax Reform Act)
for being passed despite violations of the internal rules of the House of Representatives
(HOR).
Petitioners, members of the HOR, brought this suit against respondents De
Venecia (speaker of the House), et al, on the ground that R.A. No. 8240 is null and void
because it was passed in violation of the rules of the House; that these rules embody the
"constitutional mandate" in Art. VI, Section 16(3) that "each House may determine the
rules of its proceedings" and that, consequently, violation of the House rules is a violation
of the Constitution itself. Petitioners alleged that during the proceedings, he was
effectively prevented from questioning the presence of a quorum and that the session
was hastily adjourned, and the bill certified by Speaker De Venecia to prevent petitioner
from formally challenging the existence of a quorum and asking for a reconsideration.
Respondents' defense is anchored on the principle of separation of powers and
the enrolled bill doctrine. They argued that enforcement of the rules cannot be sought in
the courts except insofar as they implement constitutional requirements such as that
relating to three readings on separate days before a bill may be passed.

Issue: Whether or not the Congress committed a grave abuse of discretion in enacting
R.A. No. 8240.

Ruling: NO.
In this case, no rights of private individuals are involved but only those of a member
who, instead of seeking redress in the House, chose to transfer the dispute to this Court.
We have no more power to look into the internal proceedings of a House than members
of that House have to look over our shoulders, as long as no violation of constitutional
provisions is shown.
Petitioners must realize that each of the three departments of our government has
its separate sphere which the others may not invade without upsetting the delicate
balance on which our constitutional order rests. Due regard for the working of our system
of government, more than mere comity, compels reluctance on our part to enter upon an
inquiry into an alleged violation of the rules of the House. We must accordingly decline
the invitation to exercise our power.
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 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 petitioners can find their
remedy in that department itself.
WHEREFORE, the petition for certiorari and prohibition is DISMISSED.