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Joker P. Arroyo, Edcel C. Lagman, John Henry R. Osmea, Wigberto E.

Taada, and 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
Mendoza, J. (14 August 1997)
Facts:
House Bill No. 7198 was approved on third reading on September 12, 1996,
and then passed to the Senate on September 16, 1996, 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. That same day, while Rep.
Sarmiento was interpellating, Rep. Arroyo moved to adjourn for a lack of quorum.
After a head count, the chair of the bicameral conference committee, Deputy
Speaker Daza, declared a quorum. Rep. Arroyo appealed, but his motion was voted
down. During subsequent interpellation, Rep. Arroyo announced that he would
question the quorum, but he never did. Rep. Arroyo then made an objection, but,
after a brief suspension of session, the House adjourned until the next week. That
same day, the bill was signed by the Speaker of the House of Representatives and
the President of the Senate, and was certified by the respective secretaries of both
Houses of Congress. This enrolled bill was signed into law by President Fidel V.
Ramos on November 22, 1996.
As members of the House of Representatives, the petitioners brought the suit
against the respondents, charging violation of the rules of the House, which
petitioners allege are constitutionally mandated. They charge that the Chair
violated of Rule VIII, 35 and Rule XVII, 103 of the Rules of the House, the Chair, by
not call for the yeas or nays in submitting the conference committee report to the
House, violated Rule XIX, 112 by deliberately ignoring Rep. Arroyos question and
did not repeat Rep. Albanos motion to approve or ratify, violated Rule XVI, 9 by
refusing to recognize Rep. Arroyo, proceeding to act on Rep. Albanos motion, and
then declaring the report approved, and violated Rule XX, 121-122, Rule XXI, 123,
and Rule XVIII, 109 by suspending the session without first ruling on Rep. Arroyos
question.
Issue: Whether or not Congress is constitutionally required to follow its internal
rules of procedure in passing laws
Held: Congress can disregard its own internal rules in passing a law.
Ratio:
The courts cannot inquire into allegations that, in enacting a law, a House of
Congress failed to comply with its own rules, in the absence of a violation of the
Constitution or the rights of private individuals. Parliamentary rules are also merely
procedural, and the courts are not concerned with their observance. They may be
waived or disregarded by Congress. These rules are subject to revocation,
modification or waiver at the pleasure of Congress, unless the construction to be

given to a rule affects persons other than members of the legislative body the
question presented is necessarily judicial in character. No rights of private
individuals were affected in this case, so Congress cannot be called to task in
disregarding its own rules.

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