Arroyo, et al.

De Venecia
Art 6. Sec 16. / Officers

Facts:
This is a petition for certiorari challenging the validity of 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.
Petitioners suit against respondents charging violation of the rules of the
House which petitioners claim are constitutionally mandated so that
their violation is tantamount to a violation of the constitution.
During interpellation, Rep. arroyo announced that he was going to raise a
question on the quorum, although until the end of his interpellation he
never did.
Petitioner claim that there are actually four different versions of the
transcript of this portion of Rep. arroyos interpellation. However, in
order to expedite the resolution of the petition, they admit the
correctness of the transcripts relied upon by the respondents.

Issues:
WON RA 8240 is null and void because it was passed in violation of the rules
of the House under the constitutional mandate of Art. VI, Sec. 16.

Specifically, violation of
Rule 8, sec 35 and Rule 17, sec.103 of the rule of the house. (Chair
not asking for yeas or nays, but simply asked for approval)
Rule 19, Sec. 112, 3 (Chair ignores petitioners query)
Rule 16, Sec. 97 (Chair refused to recognize petitioner)
Rule 20, sec. 112-122, Rule 21, Sec.123, Rule 18, sec.109
(suspension of session without ruling first on petitioners query, a
point of order or a privileged motion.)

Held:
Case dismissed

Ratio:

1. What have been violated in the enactment of RA 8240 are merely internal
rules of procedure of the House rather than constitutional requirements
for the enactment of a law.
In Osmena v. Pendatun, it has been said that parliamentary rules
are merely procedural, and with their observance, the courts have
no concern May be waived or disregarded by the legislative
body.
Petitioners must realize that each of the 3 departments of our
government has its own separate sphere

2. Under Art.8, sec.1, nothing involving abuse of discretion amounting to
lack or excess of jurisdiction is beyond judicial review. But the courts
function is merely to check whether or not the governmental branch has
gone beyond the constitutional limits of its jurisdiction, not that it erred
or has a different view. Absence of a showing, there is no occasion for the
court to exercise its corrective power.

3. The passage of the law was not railroaded.
No rule of the HoR has been cited which specifically requires that in
cases such as this involving approval of a conference committee
report, the chair must reinstate the motion and conduct a viva voce or
nominal voting.
Nor does the constitution require that the yeas and the nays of the
members be taken every time a house has to vote

4. Under the enrolled bill doctrine, the signing of H.No. 7198 are conclusive
of its due enactment.