Astorga v.

Villegas
G.R. No. L-23475 April 30, 1974
Makintal, C.J

Facts.

House passed the Revised Manila City Charter on third reading. It submitted the bill to Senate
for concurrence. On first reading, Senator Roxas had certain amendments about the City Engineer instead
of the President Pro-tempore succeeding the Vice Mayor. Senator Tolentino also had proposed some
amendment. Upon discussion of the bill, the Senate adopted Tolentino’s amendments but did not act on
Roxas’s. Such is written in the journal. Senate returned the bill to the House for inclusion of the
amendments, but in the bill submitted to House, the amendments included and said to be approved therein
were Roxas’s, not Tolentino’s. Not privy to the mistake, House made copies of the bill, and sent one to
the President. Pres. signed bill into law.

After the law’s ratification and later implementation, Tolentino issued a press release about the error in
amendment inclusion. Quickly, the Senate President recognized the mistake and invalidated his signature
to the bill quipping that the enrolled bill was not the bill they agreed to. The Pres. also withdrew his
signature.

In response to all this, Mayor issued a circular informing his office of the change to the extent of recalling
police force assigned to the Vice Mayor due to the Act. Vice Mayor files this present petition arguing that
the bill is valid following the enrolled bill doctrine.

Issue.

Is the Revised Manila City Charter valid?

Held.

It is not valid because the attestation was neutralized by the signature invalidation. The enrolled
bill doctrine provides that despite clerical errors in the enrolled bill, its ratification gives it enforceable
authority. The journal entry rule, meanwhile, follows the agreed upon decisions of the
committees.Though the court had deliberated on which between the enrolled bill doctrine and journal
entry rule should be followed, the entry journal rule in this case prevailed. The problem here is whether
the passed bill was the same text as that approved by the Senate. Looking at the journal entries proved
that it is not. It being not the same bill, attestation can be invalidated as was done by the Senate President
in this case. Such invalidation then results to no attestation at all. With no attestation, the bill cannot be
said to have been enacted into law.

The Court cannot take any risk undertaking such as to incorporate amendments into law similar to  CPC v.
Gimenez. But it can, as in this present case, determine if the law passed was the same as the bill approved.