Arroyo vs.

De Venecia
Main Point: The law stands as it is, even though it may have been passed in violation of the rules of
procedure of the congress – because it was approved by the assembly and the president. The court
cannot touch on political questions; it cannot declare an act of legislature void on account of non-
compliance with the rules made by itself.

Facts: An amendment to the National Internal Revenue Code was introduced to the House of
Representatives involving taxations on the manufacture and sale of beer and cigarettes. This was later
passed accordingly and brought to the House of Senate. Upon the interpellation on the second reading,
herein petitioner moved for adjournment for lack of quorum which is constitutionally needed to
conduct business. Petitioner’s motion was defeated and was railroaded. The bill was then signed into
law by President Fidel Ramos.

Issue: Whether or not the law passed on violation on the constitutional mandate.

Held: There is no rule of the House concerned that quorum shall be determined by viva voce or nominal
voting. The Constitution does not require that the yeas and nays of the Members be taken every time a
House has to vote, except only on the following instances upon the last and the third readings of the bill,
at the request of 1/5 of the Members present and in passing a bill over the veto of the President.
Second, there is obviousness on the part of the petitioner to delay the business of the House, thus
eliminating the alleged skullduggery on part of the accused. Third, the enrolled bill doctrine states that
enrolled bills are in itself conclusive thus legally binding provided it is in harmony with the constitution.
Lastly, the court upheld principle of separation of powers, which herein, is applicable for the legislative
branch for it has exercised its power without grave abuse of discretion resulting to lack or excess of
jurisdiction.