Status: Still incomplete

Name of digest maker: Cedric Severino

Subject: STATCON
Topic: Statues, Bicameral, Power of the Senate to propose amendments to revenue
bills, amendments to housebills, the presidents certification, the conference
committee

Title of the Case: Tolentino v Secretary of Finance

GR No. 115455
Promulgation Date: Oct 30, 1995

Petitioner: Arturo M. Tolentino

Respondent: Secretary of Finance and Commission on Internal Revenue
Petition: Petition seeking to declare RA 7716 (Expanded VAT Tax Law)
unconstitutional

I. Power of the Senate to propose amendments to revenue bills. Petitioner reiterates

previous claims that RA 7716 did not originate exclusively in the HoR as required by
Section 24, Article VI of the Constitution. After the house bill was passed onto the
senate after its 3rd reading from the HoR, the Senate passed its own version which it
approved on May 24, 1994.

Petition has no merit.

Although Section 24 Article 24 provides that all appropriation, revenue or tariff

bills, bills authorizing increase of public debt, bills of local application, and private
bills must “originate exclusively in the HoR”, it also adds, “but the Senate may
propose or concur with amendments” In the exercise of its power, the Senate may
propose an entirely new bill as a substitute measure.

II. Amendments to House bills. Petitioner’s basic error is that they assume that the
Senate bill is an independent and distinct bill from the House bill. The provisions in
the Senate bill appear to be mere amendments of the corresponding provisions of
the House bill. Without the House bill, the Senate could not have enacted the Senate
bill. The House Bill in its original form need not be passed onto the Senate on second
and third reading. It was enough that after it was passed on first reading, it was
referred to the Senate Committee on Ways and Means. Neither was it required that
the Senate bill be passed by the HoR before the two bills could be referred to the
Conference Committee.

Notes:

Art. VI, §24 of our Constitution reads:

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.