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    Mabanag Vs Lopez-Vito 78 Phil 1 (1947) Facts

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    Dawn Jessa Go
    The document summarizes 3 Philippine Supreme Court cases that dealt with the enrolled bill doctrine: 1) Mabanag vs Lopez-Vito upheld the enrolled bill doctrine and did not consider claims of irregularities in the passage of a law. 2) Arroyo vs De Venecia also upheld the enrolled bill doctrine and would not invalidate a law based on alleged violations of legislative rules. 3) CPCC vs Gimenez relied on the enrolled bill doctrine in interpreting a law, refusing to consider claims that the terms in the enrolled bill were mistaken.

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    Mabanag Vs Lopez-Vito 78 Phil 1 (1947) Facts

    Uploaded by

    Dawn Jessa Go
    47 views3 pages
    The document summarizes 3 Philippine Supreme Court cases that dealt with the enrolled bill doctrine: 1) Mabanag vs Lopez-Vito upheld the enrolled bill doctrine and did not consider claims of irregularities in the passage of a law. 2) Arroyo vs De Venecia also upheld the enrolled bill doctrine and would not invalidate a law based on alleged violations of legislative rules. 3) CPCC vs Gimenez relied on the enrolled bill doctrine in interpreting a law, refusing to consider claims that the terms in the enrolled bill were mistaken.

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    The document summarizes 3 Philippine Supreme Court cases that dealt with the enrolled bill doctrine: 1) Mabanag vs Lopez-Vito upheld the enrolled bill doctrine and did not consider claims of irregularities in the passage of a law. 2) Arroyo vs De Venecia also upheld the enrolled bill doctrine and would not invalidate a law based on alleged violations of legislative rules. 3) CPCC vs Gimenez relied on the enrolled bill doctrine in interpreting a law, refusing to consider claims that the terms in the enrolled bill were mistaken.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    47 views3 pages

    Mabanag Vs Lopez-Vito 78 Phil 1 (1947) Facts

    Uploaded by

    Dawn Jessa Go
    The document summarizes 3 Philippine Supreme Court cases that dealt with the enrolled bill doctrine: 1) Mabanag vs Lopez-Vito upheld the enrolled bill doctrine and did not consider claims of irregularities in the passage of a law. 2) Arroyo vs De Venecia also upheld the enrolled bill doctrine and would not invalidate a law based on alleged violations of legislative rules. 3) CPCC vs Gimenez relied on the enrolled bill doctrine in interpreting a law, refusing to consider claims that the terms in the enrolled bill were mistaken.

    Copyright:

    © All Rights Reserved
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    Download as docx, pdf, or txt
    of 3

    (41) Mabanag vs Lopez-Vito

    78 Phil 1 (1947)

    Facts:

    Petitioners, three senators and eight representatives, filed a petition for


    prohibition to prevent the enforcement of a congressional resolution proposing an
    amendment to the Constitution. Petitioners, on account of alleged irregularities in
    their election, were not allowed to take part in the passage of the questioned
    resolution, nor was their membership reckoned within the computation of the votes.
    Said resolution was

    Issue:
    WON the enforcement of the congressional resolution is Constitutional
    considering Petitioner’s contention that if their votes had been counted, the
    affirmative votes in favour of the proposed amendment would have been short of the
    necessary three-fourths vote in either branch of Congress, and considering further the
    Respondent’s contention which relies on the conclusiveness on the courts of an
    enrolled bill or resolution.

    Held:
    Yes, it is constitutional.

    Enrolled Bill Doctrine pertains to the rule that, in the case of Acts of the
    Philippine Legislature, when there is an existence of a copy signed by the presiding
    officers and secretaries of said bodies, it shall be conclusive proof of the provisions of
    such Acts and of the due enact thereof.

    In this case, the Court did not find any signs of irregularity in the passage of the
    law and did not bother itself with considering the effects of an authenticated copy if
    one had been introduced. Therefore, the Court will respect the certification of the
    presiding officers that a bill has been duly passed.

    (Digester’s Note: Guys, nalisuran ko aning case ba mao na di jud ko sure sa akong digest.
    Sensya jud. Huhu)
    (42) Arroyo vs De Venecia
    GR No. 127255 (14 August 1997)

    Facts:
    Petitioners filed a petition for certiorari and prohibition challenging the validity
    of R.A. No. 8240. During the interpellations, Petitioner objected to the Majority
    Leader’s motion, however, the approval of the conference committee report had by
    then already been declared by the Chair. 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. The enrolled bill was signed
    into law by the President.

    Issue:
    WON the Republic Act is null and void considering Petitioner’s contention that
    its passage violated the rules of the House by not recognizing Petitioner’s objections,
    which they claim are “constitutionally-mandated”, and considering further
    Respondent’s contention that there is no justification for reconsidering the enrolled
    bill doctrine.

    Held:
    No, the Republic Act is not null and void.

    As it was held in Marshall Field & Co. v. Clark, The enrolled bill rule rests on the
    following considerations that an enrolled Act having the official attestations of the
    Speaker of the House of Representatives, of the President of the Senate, and of the
    President, carries, on its face, a solemn assurance by the legislative and executive
    departments of the government, charged, respectively, with the duty of enacting and
    executing the laws, that it was passed by Congress. The respect due to coequal and
    independent departments requires the judicial department to act upon that assurance,
    and to accept, as having passed Congress, all bills authenticated in the manner stated;
    leaving the court to determine, when the question properly arises, whether the Act,
    so authenticated, is in conformity with the Constitution.

    In this case, the Court held that held it would be an unwarranted invasion of the
    prerogative of a coequal 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, or to allow those defeated in the political arena to seek a rematch in the
    judicial forum when petitioners can find their remedy in that department itself. To
    disregard the enrolled bill rule would be to disregard the respect due to the other
    departments of the government.
    (43) CPCC vs Gimenez
    7 SCRA 347 (1963)

    Facts:
    Petitioner was engaged in the production of synthetic resins using raw
    materials, urea and formaldehyde, as main components which are being imported
    abroad. Petitioner paid the required margin fee to the Central Bank of the Philippines,
    for the importation of said raw materials, but later on, had sought the refund relying
    upon Republic Act No. 2069 which states that the importation of “Urea formaldehyde”
    is exempt from payment of aforementioned margin fee.

    Issue:
    WON “urea” and “formaldehyde” are exempt by law from the payment of the
    aforementioned margin fee, considering Petitioner’s contention that the term “urea
    formaldehyde” appearing in the provision should be construed as “urea and
    formaldehyde”, and considering further, the Respondent’s contention that the
    enrolled bill, however, used the term “urea formaldehyde”.

    Held:
    No, “urea” and “formaldehyde” are not exempt by law from the payment of
    the aforementioned margin fee.

    Enrolled Bill Doctrine pertains to the rule that, in the case of Acts of the
    Philippine Legislature, when there is an existence of a copy signed by the presiding
    officers and secretaries of said bodies, it shall be conclusive proof of the provisions of
    such Acts and of the due enact thereof.

    In this case, the enrolled bill, which uses the term “urea formaldehyde” instead
    of “urea and formaldehyde”, is conclusive upon the courts as regards the tenor of the
    measure passed by Congress and approved by the President. If there has been any
    mistake in the printing of the bill before it was certified by the officers of Congress and
    approved by the Executive, on which the court cannot speculate, without jeopardizing
    the principle of separation of powers and undermining one of the cornerstones of the
    democratic system. Therefore, the court held that the remedy is by amendment or
    curative legislation, not by judicial decree.

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