G.R. No.

115455

TOLENTINO V SECRETARY OF FINANCE

FACTS

RA 7716, otherwise known as the Expanded Value-Added Tax Law, is an act that
seeks to widen the tax base of the existing VAT system and enhance its
administration by amending the National Internal Revenue Code. There are various
suits questioning and challenging the constitutionality of RA 7716 on various
grounds.

Tolentino contends that RA 7716 did not originate exclusively from the House of
Representatives but is a mere consolidation of HB. No. 11197 and SB. No. 1630
and it did not pass three readings on separate days on the Senate thus violating
Article VI, Sections 24 and 26(2) of the Constitution, respectively.

Art. VI, Section 24: All appropriation, revenue or tariff bills, bills authorizing increase
of the public debt, bills of local application, and private bills shall originate
exclusively in the House of Representatives, but the Senate may propose or concur
with amendments.

Art. VI, Section 26(2): No bill passed by either House shall become a law unless it
has passed three readings on separate days, and printed copies thereof in its final
form have been distributed to its Members three days before its passage, except
when the President certifies to the necessity of its immediate enactment to meet a
public calamity or emergency. Upon the last reading of a bill, no amendment
thereto shall be allowed, and the vote thereon shall be taken immediately
thereafter, and the yeas and nays entered in the Journal.

ISSUE

Whether or not RA 7716 violated Art. VI, Section 24 and Art. VI, Section 26(2) of
the Constitution.

HELD

No. The phrase “originate exclusively” refers to the revenue bill and not to the
revenue law. It is sufficient that the House of Representatives initiated the passage
of the bill which may undergo extensive changes in the Senate.
SB. No. 1630, having been certified as urgent by the President need not meet the
requirement not only of printing but also of reading the bill on separate days.