ARROYO VS DE VENECIA

Joker P. Arroyo, Edcel C. Lagman, John Henry R. Osmena, Wigberto E. Tanada, Ronaldo B. Zamora,
petitioners VS Jose de Venecia, Raul Daza, Rodolfo Albano, the executive secretary, the secretary of
finance, and the commissioner of internal revenue, respondents

GR NO. 127255 AUG. 14, 1997

MENDOZA, J.
FACTS:
A petition was filed for certiorari and/or prohibition challenging the validity of Republic Act
No. 8240, which amends certain provisions of the National Internal Revenue Code by imposing
so-called sin taxes (actually specific taxes) on the manufacture and sale of beer and cigarettes.
The law originated in the House of Representatives as H. No. 7198. This bill was approved on
third reading on September 12, 1996 and transmitted on September 16, 1996 to the Senate
which approved it with certain amendments on third reading on November 17, 1996. A
bicameral conference committee was formed to reconcile the disagreeing provisions of the
House and Senate versions of the bill. The bicameral conference committee submitted its report
to the House on November 21, 1996. During interpellations, Rep. Arroyo made an interruption
and moved to adjourn for lack of quorum. Rep. Antonio Cuenco objected to the motion and
asked for a head count. After a roll call, the Chair (Deputy Speaker Raul Daza) declared the
presence of a quorum. Rep. Arroyo appealed the ruling of the Chair, but his motion was
defeated when put to a vote. In the course of his 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.
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.
ISSUE:
Whether or not the passage of RA 8240 was valid given that there was a noncompliance
with the rules of the House.
HELD:
YES. It would be an unwarranted invasion of the prerogative of a co-equal 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.
As suggested, the petitioners can seek the enactment of a new law or the repeal or
amendment of R.A. No. 8240. In the absence of anything to the contrary, the Court must
assume that Congress or any House thereof acted in the good faith belief that its conduct was
permitted by its rules, and deference rather than disrespect is due the judgment of that body.