When Can Courts Interfere with Internal Legislative Rules?

G.R. No. 127255, August 14, 1997

Imagine a law being questioned not because of its content, but because of how it was passed. In the Philippines, the principle of separation of powers generally prevents courts from interfering with the internal rules of the legislative branch. However, there are exceptions. The Supreme Court case of Arroyo vs. De Venecia delves into the extent to which courts can review the legislative process, specifically concerning the passage of Republic Act No. 8240, which imposed specific taxes on beer and cigarettes.

This case revolves around the argument that the House of Representatives violated its own rules during the passage of the law, leading petitioners to claim a violation of the Constitution. The central legal question is whether the courts have the power to inquire into allegations of non-compliance with internal legislative rules when enacting a law.

The Enrolled Bill Doctrine and Legislative Autonomy

The legal context of this case is deeply rooted in the principle of separation of powers and the enrolled bill doctrine. The enrolled bill doctrine essentially states that a bill, once signed by the leaders of Congress and certified by the secretaries of both houses, is considered conclusive proof of its due enactment.

This doctrine is based on the idea that the judicial branch should respect the actions of the legislative branch. The Constitution grants each house of Congress the power to determine its own rules of proceedings. Article VI, Section 16(3) of the 1987 Constitution states:

“Each House may determine the rules of its proceedings…”

However, this power is not absolute. Courts can intervene if there is a violation of a constitutional provision or the rights of private individuals. The key question is whether the alleged violations in this case rise to that level.

The Case of Arroyo vs. De Venecia: A Procedural Battle

The case started in the House of Representatives with H. No. 7198. After passing through the House and Senate, a bicameral conference committee reconciled differing provisions. The petitioners, members of the House, alleged that several House rules were violated during the approval of the conference committee report:

• The Chair did not call for yeas or nays, preventing Rep. Arroyo from questioning the quorum.
• The Chair ignored Rep. Arroyo’s question and did not repeat the motion to approve the report.
• The Chair refused to recognize Rep. Arroyo and declared the report approved.
• The Chair suspended the session without ruling on Rep. Arroyo’s question.

The petitioners argued that these violations invalidated R.A. No. 8240. The respondents, including the Speaker of the House and other government officials, countered that the Court should not interfere with the internal rules of the House and that the enrolled bill doctrine should apply.

During the session, a key moment occurred when Rep. Arroyo attempted to raise a question. According to the Court’s decision:

“What happened is that, after Rep. Arroyo’s interpellation of the sponsor of the committee report, Majority Leader Rodolfo Albano moved for the approval and ratification of the conference committee report. The Chair called out for objections to the motion. Then the Chair declared: “There being none, approved.” At the same time the Chair was saying this, however, Rep. Arroyo was asking, “What is that . . . Mr. Speaker?” The Chair and Rep. Arroyo were talking simultaneously.”

The Court ultimately sided with the respondents, emphasizing the importance of respecting the autonomy of the legislative branch. The Court stated:

“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.”

The petition was dismissed, upholding the validity of R.A. No. 8240.

Practical Implications: Respecting Legislative Processes

This ruling reinforces the enrolled bill doctrine and the principle of separation of powers in the Philippines. It clarifies that courts should generally not interfere with the internal rules and procedures of the legislative branch unless there is a clear violation of the Constitution or the rights of private individuals.

This case serves as a reminder that challenges to laws based on procedural grounds face a high hurdle. Litigants must demonstrate a significant constitutional violation, not merely a deviation from internal legislative rules.

Key Lessons:

• Courts respect the autonomy of the legislative branch in determining its own rules.
• The enrolled bill doctrine provides a strong presumption of validity for duly enacted laws.
• Challenges based on procedural grounds require demonstrating a constitutional violation.

Frequently Asked Questions (FAQ)

Q: What is the enrolled bill doctrine?

A: The enrolled bill doctrine states that a bill, once signed by the leaders of Congress and certified by the secretaries of both houses, is considered conclusive proof of its due enactment.

Q: When can courts interfere with internal legislative rules?

A: Courts can interfere if there is a violation of a constitutional provision or the rights of private individuals.

Q: What is “grave abuse of discretion”?

A: “Grave abuse of discretion” means such capricious and whimsical exercise of judgment by a tribunal exercising judicial or quasi judicial power as to amount to lack of power.

Q: Does the Constitution require that the yeas and nays of the Members be taken every time a House has to vote?

A: No, the Constitution only requires that the yeas and the nays of the Members be taken every time a House has to vote in the following instances: upon the last and third readings of a bill, at the request of one-fifth of the Members present, and in repassing a bill over the veto of the President.

Q: What is the role of the Journal of the House of Representatives?

A: Each House shall keep a Journal of its proceedings, and from time to time publish the same, excepting such parts as may, in its judgment, affect national security; and the yeas and nays on any question shall, at the request of one-fifth of the Members present, be entered in the Journal.

Q: What should I do if I believe a law was passed in violation of the Constitution?

A: Consult with a qualified attorney to assess the specific facts and determine the appropriate legal course of action.

ASG Law specializes in constitutional law and legislative procedures. Contact us or email hello@asglawpartners.com to schedule a consultation.