ARTURO TOLENTINO VS.

SECRETARY OF FINANCE
G.R. No. 115455 - August 25, 1994

Facts:
Petitioner Tolentino, filed a certiorari for the court to reconsider the decision dismissing
the petitions totaling of ten suits filed for the declaration of R.A. No. 7716, otherwise
known as the Expanded Value-Added Tax Law's unconstitutionality. As per him, R.A.
No. 7716 did not “originate exclusively” in the House of Representatives as required by
the Constitution as it was a version proposed by the Senate; The petitioner argued that
the Bill must retain the essence of H. No. 11197 to comply with the constitution.
Furthermore, Although H. No. 11197 was indeed filed in the House of Representatives
and has passed three readings therein. It was sent to the Senate and was approved on
May 24, 1994 as S. No. 1630 after passing only for the first reading in a day, not
complying to the constitution by having to pass “three readings on separate days” due.
Issues:
1. Whether or not R.A. No. 7716 violated Article VI, Section 24 of the Philippine
Constitution which 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.”

2. Whether or not the same Act violated Art. VI, Section 26(2) of the Constitution
which reads: “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.”
Ruling:
1. No. Without H. No. 11197, the Senate could not have enacted S. No. 1630.
Because the Senate bill was a mere amendment of the House bill, H. No. 11197.
It is not the law — but the revenue bill — which is required by the Constitution to
“originate exclusively” in the House of Representatives. It is important to
emphasize this, because a bill originating in the House may undergo such
extensive changes in the Senate that the result may be are writing of the whole.
At this point, what is important to note is that, as a result of the Senate action, a
 distinct bill may be produced. To insist that a revenue statute and not only
the bill which initiated the legislative process culminating in the enactment of the
law must substantially be the same as the House bill would be to deny the
Senate’s power not only to concur with amendments but also to propose
amendments.
2. No. It is enough that the President certified the bill which, at the time he makes
the certification, is under consideration. Enough has been said to show that it
was within the power of the Senate to propose S. No. 1630. We not pass to the
next argument of petitioners that S. No.1630 did not pass three readings on
separate days as required by the Constitution because the second and third
readings were done on the same day, March 24,1994. But this was because on
February 24, 1994 and again on March 22, 1994, the President had certified S.
No.1630 as urgent. Moreover, the presidential certification dispensed with the
requirement not only of printing but also that of reading the bill on separate days.
The phrase “except when the President certifies to the necessity of its immediate
enactment, etc.” in Art. VI, 26(2) qualified the two stated conditions before a bill
can become a law: (i) the bill has passed three readings on separate days and
(ii) it has been printed in its final form and distributed three days before it is finally
approved.