#CASE NO.

7
DATU MICHAEL ABAS KIDA v. SENATE OF THE PHILIPPINES
G.R. No. 196271

FACTS Republic Act (RA) No. 10153 was enacted, resetting the next
ARMM regular elections to May 2013. Congress promulgated the
Republic Act (RA) No. 6734 which is the organic act that
established the ARMM and scheduled the first regular elections
for the ARMM regional officials. Following aforementioned article
is the RA No. 9054 which amended the ARMM Charter and reset
the regular elections for the ARMM regional officials. RA No. 9140
further reset the first regular elections.

RA No. 9333 reset for the third time the ARMM regional elections
to the 2nd Monday of August 2005 and on the same date every 3
years thereafter. Pursuant to RA No. 9333, the next ARMM
regional elections should have been held on August 8,
2011.

The petitioners assailing RA No. 9140, RA No. 9333 and RA No.

10153 assert that
these laws amend RA No. 9054 and thus, have to comply with the
supermajority
vote and plebiscite requirements prescribed under RA No. 9094
in order to
become effective.
ISSUE Whether or not the supermajority voting requirement of RA No.
9054 is constitutional
RULING Petition is DISMISSED.
Supermajority voting requirement is unconstitutional for giving
RA No. 9054 the character of an irrepealable law by requiring
more than what the Constitution demands.

Section 16(2), Article VI of the Constitution provides that a

"majority of each House shall constitute a quorum to do
business." In other words, as long as the majority of
the members of the House of Representatives or the Senate are
present, these bodies have the quorum needed to conduct
business and hold sessions. Within a
quorum, a vote of majority is generally sufficient to enact laws or
approve acts.

In contrast, RA No. 9054 requires a vote of no less than two-

thirds (2/3) of the
Members of the House of Representatives and of the Senate.
 Clearly, this 2/3
voting requirement is higher than what the Constitution requires
for the passage
of bills, and served to restrain the plenary powers of Congress to
amend, revise or repeal the laws it had passed.

Thus, while a supermajority is not a total ban against a repeal, it

is a limitation in
excess of what the Constitution requires on the passage of bills
and is
constitutionally obnoxious because it significantly constricts the
future legislators’
room for action and flexibility.

CASE NO. 9

CASE DIGEST: CIVIL LIBERTIES UNION VS EXECUTIVE SECRETARY, G.R. No.

83896, February 22, 1991

FACTS In July 1987, the President Corazon Aquino issued Executive

Order No. 284 which allowed members of the Cabinet, their
undersecretaries and assistant secretaries to hold other
government offices or positions in addition to their primary
positions subject to limitations set therein. The Civil Liberties
Union (CLU) assailed this EO averring that such law is
unconstitutional. The constitutionality of EO 284 is being
challenged by CLU on the principal submission that it adds
exceptions to Sec 13, Article 7 of the Constitution which provides:

“Sec. 13. The President, Vice-President, the Members of the

Cabinet, and their deputies or assistants shall not, unless
otherwise provided in this Constitution, hold any other office
or employment during their tenure. They shall not, during said
tenure, directly or indirectly practice any other profession,
participate in any business, or be financially interested in any
contract with, or in any franchise, or special privilege granted by
the Government or any subdivision, agency, or instrumentality
thereof, including government-owned or controlled corporations
or their subsidiaries. They shall strictly avoid conflict of interest
in the conduct of their office.”

CLU avers that by virtue of the phrase “unless otherwise provided

in this Constitution“, the only exceptions against holding any other
office or employment in Government are those provided in the
 Constitution, namely: (i) The Vice-President may be appointed as
a Member of the Cabinet under Sec 3, par. (2), Article 7; and (ii)
the Secretary of Justice is an ex-officio member of the Judicial and
Bar Council by virtue of Sec 8 (1), Article 8
ISSUES Whether or not EO 284 is constitutional.
RULING No, it is unconstitutional. It is clear that the 1987 Constitution
seeks to prohibit the President, Vice-President, members of the
Cabinet, their deputies or assistants from holding during their
tenure multiple offices or employment in the government, except
in those cases specified in the Constitution itself and as above
clarified with respect to posts held without additional
compensation in an ex-officio capacity as provided by law and as
required by the primary functions of their office, the citation of
Cabinet members (then called Ministers) as examples during the
debate and deliberation on the general rule laid down for all
appointive officials should be considered as mere personal
opinions which cannot override the constitution’s manifest intent
and the people’s understanding thereof.

In the light of the construction given to Sec 13, Art 7 in relation to

Sec 7, par. (2), Art IX-B of the 1987 Constitution, EO 284 is
unconstitutional. Ostensibly restricting the number of positions
that Cabinet members, undersecretaries or assistant secretaries
may hold in addition to their primary position to not more than 2
positions in the government and government corporations, EO
284 actually allows them to hold multiple offices or employment
in direct contravention of the express mandate of Sec 13, Art 7 of
the 1987 Constitution prohibiting them from doing so, unless
otherwise provided in the 1987 Constitution itself.

CASE NO. 10

FRANCISCO V. HOUSE OF REPRESENTATIVES (G.R NO. 160261)

FACTS On July 22, 2002, the House of Representatives adopted a Resolution...

which directed the Committee on Justice "to conduct an investigation,
in aid of legislation, on the... manner of disbursements and
expenditures by the Chief Justice of the Supreme Court of the Judiciary
Development Fund
On June 2, 2003, former President Joseph E. Estrada filed an
impeachment complaint[4] (first impeachment complaint) against
Chief Justice Hilario G. Davide Jr. and seven Associate Justices[5] of this
Court for "culpable violation of the Constitution, betrayal of the public
trust and other high crimes."[6] The complaint was endorsed by
Representatives Rolex T. Suplico, Ronaldo B.
Zamora and Didagen Piang Dilangalen,[7] and was referred to the
House Committee on Justice on August 5, 2003[8] in accordance with
Section 3(2) of Article XI of the Constitution
The House Committee on Justice ruled on October 13, 2003 that the
first impeachment complaint was "sufficient in form,"[9] but voted to
dismiss the same on October 22, 2003 for being insufficient in
substance.
Four months and three weeks since the filing on June 2, 2003 of the
first complaint or on October 23, 2003, a day after the House
Committee on Justice voted to dismiss it, the second impeachment
complaint [11] was filed with the
Secretary General of the House[12] by Representatives Gilberto C.
Teodoro, Jr. (First District, Tarlac) and Felix William B. Fuentebella
(Third District, Camarines Sur) against Chief Justice Hilario G. Davide,
Jr., founded on the... alleged results of the legislative inquiry initiated by
above-mentioned House Resolution. This second impeachment
complaint was accompanied by a "Resolution of
Endorsement/Impeachment" signed by at least one-third (1/3) of all
the Members of the House of
Representatives.[13]
Thus arose the instant petitions against the House of Representatives,
et. al., most of which petitions contend that the filing of the second
impeachment complaint is unconstitutional as it violates the provision
of Section 5 of Article XI of the Constitution that
"[n]o impeachment proceedings shall be initiated against the same
official more than once within a period of one year."
To determine the merits of the issues raised in the instant petitions,
this Court must necessarily turn to the Constitution itself which
employs the well-settled principles of constitutional construction.
First, verba legis, that is, wherever possible, the words used in the
Constitution must be given their ordinary meaning except where
technical terms are employed. Thus, in J.M. Tuason & Co., Inc. v. Land
Tenure Administration,[36] this Court, speaking through Chief Justice
Enrique Fernando, declared:
We look to the language of the document itself in our search for its
meaning. We do not of course stop there, but that is where we begin. It
is to be assumed that the words in which constitutional provisions are
couched express the objective sought... to be attained. They are to be
given their ordinary meaning except where technical terms are
employed in which case the significance thus attached to them prevails.
As the Constitution is not primarily a lawyer's document, it being
essential for the rule of law... to obtain that it should ever be present in
the people's consciousness, its language as much as possible should be
understood in the sense they have in common use. What it says
according to the text of the provision to be construed compels
acceptance and negates... the power of the courts to alter it, based on
the postulate that the framers and the people mean what they say. Thus
these are the cases where the need for construction is reduced to a
minimum.[37] (Emphasis and underscoring... supplied)
Second, where there is ambiguity, ratio legis est anima. The words of
the Constitution should be interpreted in accordance with the intent of
its framers. And so did this Court apply this principle in Civil Liberties
Union v. Executive Secretary[38] in this wise:
A foolproof yardstick in constitutional construction is the intention
underlying the provision under consideration. Thus, it has been held
that the Court in construing a Constitution should bear in mind the
object sought to be accomplished by its adoption, and the... evils, if any,
sought to be prevented or remedied. A doubtful provision will be
examined in the light of the history of the times, and the condition and
circumstances under which the Constitution was framed. The object is
to ascertain the reason which induced the... framers of the Constitution
to enact the particular provision and the purpose sought to be
accomplished thereby, in order to construe the whole as to make the
words consonant to that reason and calculated to effect that purpose.
[39] (Emphasis and underscoring supplied supplied)
As it did in Nitafan v. Commissioner on Internal Revenue[40] where,
speaking through Madame Justice Amuerfina A. Melencio-Herrera, it
declared:... x x x The ascertainment of that intent is but in keeping with
the fundamental principle of constitutional construction that the intent
of the framers of the organic law and of the people adopting it should
be given effect. The primary task in constitutional... construction is to
ascertain and thereafter assure the realization of the purpose of the
framers and of the people in the adoption of the Constitution. It may
also be safely assumed that the people in ratifying the Constitution
were guided mainly by the explanation... offered by the framers.[41]
(Emphasis and underscoring supplied)
Finally, ut magis valeat quam pereat. The Constitution is to be
interpreted as a whole. Thus, in Chiongbian v. De Leon,[42] this Court,
through Chief Justice Manuel Moran declared:... x x x [T]he members of
the Constitutional Convention could not have dedicated a provision of
our Constitution merely for the benefit of one person without
considering that it could also affect others. When they adopted
subsection 2, they... permitted, if not willed, that said provision should
function to the full extent of its substance and its terms, not by itself
alone, but in conjunction with all other provisions of that great
document.[43] (Emphasis and... underscoring supplied)
ISSUES whether or not the power of judicial review extends to those arising
from impeachment proceedings; (2) whether or not the essential pre-
requisites for the exercise of the power of judicial review have been
fulfilled; and (3) the substantive... issues yet remaining. These matters
shall now be discussed in seriatim.
Issue no. 1
Whether the offenses alleged in the Second impeachment complaint
constitute valid impeachable offenses under the Constitution.
Issue no. 2
Whether the second impeachment complaint was filed in accordance
with Section 3(4), Article XI of the Constitution.
Issue no. 3
Whether the legislative inquiry by the House Committee on Justice into
the Judicial Development Fund is an unconstitutional infringement of
the constitutionally mandated fiscal autonomy of the judiciary.
Issue no. 4
Whether Sections 15 and 16 of Rule V of the Rules on Impeachment
adopted by the 12th Congress are unconstitutional for violating the
provisions of Section 3, Article XI of the Constitution.
Issue no. 5
Whether the second impeachment complaint is barred under Section
3(5) of Article XI of the Constitution.

RULING The first issue goes into the merits of the second impeachment
complaint over which this Court has no jurisdiction. More importantly,
any discussion of this issue would require this Court to make a
determination of what constitutes an impeachable offense. Such a
determination is... a purely political question which the Constitution
has left to the sound discretion of the legislation. Such an intent is clear
from the deliberations of the Constitutional Commission.
Although Section 2 of Article XI of the Constitution enumerates six
grounds for impeachment, two of these, namely, other high crimes and
betrayal of public trust, elude a precise definition. In fact, an
examination of the records of the 1986 Constitutional Commission
shows that... the framers could find no better way to approximate the
boundaries of betrayal of public trust and other high crimes than by
alluding to both positive and negative examples of both, without
arriving at their clear cut definition or even a standard therefor.[114]
Clearly, the issue calls upon this court to decide a non- justiciable
political question which is beyond the scope of its judicial power under
Section 1, Article VIII.
initiation takes place by the act of filing of the impeachment complaint
and referral to the House Committee on Justice, the initial action taken
 thereon, the meaning of Section 3 (5) of Article XI becomes clear. Once
an impeachment complaint has been... initiated in the foregoing
manner, another may not be filed against the same official within a one
year period following Article XI, Section 3(5) of the Constitution.

CASE NO. 11

KILOSBAYAN v. MANUEL L. MORATO, GR No. 118910

FACTS As a result of our decision in G.R. No. 113375 (Kilosbayan,

Incorporated v. Guingona, 232 SCRA 110 (1994)) invalidating the
Contract of Lease between the Philippine Charity Sweepstakes
Office (PCSO) and the Philippine Gaming Management Corp.
(PGMC) on the... ground that it had been made in violation of the
charter of the PCSO, the parties entered into negotiations for a
new agreement that would be "consistent with the latter's [PCSO]
charter . . . and conformable to this Honorable Court's aforesaid
Decision."
On January 25, 1995, the parties signed an Equipment Lease
Agreement (hereafter called ELA) whereby the PGMC leased on-
line lottery equipment and accessories to the PCSO in
consideration of a rental equivalent to 4.3% of the gross amount
of ticket sales derived by the PCSO from... the operation of the
lottery which in no case shall be less than an annual rental
computed at P35,000.00 per terminal in commercial operation.
The rental is to be computed and paid bi-weekly. In the event the
bi-weekly rentals in any year fall short of the annual... minimum
fixed rental thus computed, the PCSO agrees to pay the deficiency
out of the proceeds of its current ticket sales.
Under the law, 30% of the net receipts from the sale of tickets is
allotted to charity. (R.A. No. L169, §6 (B))
A copy of the ELA was submitted to the Court by the PGMC in
accordance with its manifestation in the prior case.
On February 21, 1995 this suit was filed seeking to declare the
ELA invalid on the ground that it is substantially the same as the
Contract of Lease nullified in the first case.
ISSUE THE ELA IS VIOLATIVE OF SECTION 2(2), ARTICLE IX-D OF THE 1987
CONSTITUTION IN RELATION TO COA CIRCULAR NO. 85-55-A.
RULING Standing is a special concern in constitutional law because in some
cases suits are brought not by parties who have been personally
injured by the operation of a law or by official action taken, but by
concerned citizens, taxpayers or voters who actually sue in the public...
interest. Hence the question in standing is whether such parties have
"alleged such a personal stake in the outcome of the controversy as to
assure that concrete adverseness which sharpens the presentation of
issues upon which the court so largely depends for illumination... of
difficult constitutional questions."
Petitioners do not in fact show what particularized interest they have
for bringing this suit. It does not detract from the high regard for
petitioners as civic leaders to say... that their interest falls short of that
required to maintain an action under Rule 3, §2.
It is true that the present action involves not a mere contract between
private individuals but one made by a government corporation. There
is, however, no allegation that public funds are being misspent so as to
make this action a public one and justify relaxation of the...
requirement that an action must be prosecuted in the name of the real
party in interest.
the question as to "real party in interest" is whether he is "the party
who would be benefitted or injured by the judgment, or the `party
entitled to the avails of the suit.'"
in regards to legal standing

In actions for the annulment of contracts, such as this action, the real
parties are those who are parties to the agreement or are bound either
principally or subsidiarily or are prejudiced in their rights with respect
to one of the contracting parties and can show the detriment... which
would positively result to them from the contract even though they did
not intervene in it (Ibañ ez v. Hongkong & Shanghai Bank, 22 Phil. 572
(1912)), or who claim a right to take part in a public bidding but have
been, illegally excluded from it.
(See De la Lara Co., Inc. v. Secretary of Public Works and
Communications, G.R. No. L-13460, Nov. 28, 1958)
These are parties with "a present substantial interest, as distinguished
from a mere expectancy or future, contingent, subordinate, or
consequential interest. . . . The phrase `present substantial interest'
more concretely is meant such interest of a party in the subject
matter... of the action as will entitle him, under the substantive law, to
recover if the evidence is sufficient, or that he has the legal title to
demand and the defendant will be protected in a payment to or
recovery by him." (1 MORAN, COMMENTS ON THE RULERS OF COURT
154-155 (1979))
Thus, in Gonzales v. Hechanova, 118 Phil. 1065 (1963) petitioner's
right to question the validity of a government contract for the
importation of rice was sustained because he was a rice planter with
substantial production, who had a right under the law to sell to the...
government.
But petitioners do not have such present substantial interest in the ELA
as would entitle them to bring this suit. Denying to them the right to
intervene will not leave without remedy any perceived illegality in the
execution of government contracts. Questions as to the... nature or
validity of public contracts or the necessity for a public bidding before
they may be made can be raised in an appropriate case before the
Commission on Audit or before the Ombudsman. The Constitution
requires that the Ombudsman and his deputies, "as protectors... of the
people shall act promptly on complaints filed in any form or manner
against public officials or employees of the government, or any
subdivision, agency or instrumentality thereof including government-
owned or controlled corporations." (Art. XI, Sec. 12) In... addition, the
Solicitor 6eneral is authorized to bring an action for quo warranto if it
should be thought that a government corporation, like the PCSO, has
offended against its corporate charter or misused its franchise.
In the new contract the rental is also expressed in terms of percentage
of the gross proceeds from ticket sales because the allocation of the
receipts under the charter of the PCSO is also expressed in percentage,
to wit: 55% is set aside for prizes; 30% for contribution to... charity;
and 15% for operating expenses and capital expenditures. (R.A. No.
1169, §6) As the Solicitor General points out in his Comment filed in
behalf of the PCSO:
In the PCSO charter, operating costs are reflected as a percentage of the
net receipts (which is defined as gross receipts less ticket printing
costs which shall not exceed 2% and the 1% granted to the
Commission on Higher Education under Republic Act No. 7722). The...
mandate of the law is that operating costs, which include payments for
any leased equipment, cannot exceed 15% of net receipts, or 14.55% of
gross receipts.
In G.R. No. 113375 it was held that the PCSO does not have the power
to enter into any contract which would involve it in any form of
"collaboration, association or joint venture" for the holding of
sweepstakes races, lotteries and other similar activities.
This interpretation must be reexamined especially in determining
whether petitioners have a cause of action.
We hold that the charter of the PCSO does not absolutely prohibit it
from holding or conducting lottery "in collaboration, association or
joint venture" with another party. What the PCSO is prohibited from
doing is to invest in a business engaged in sweepstakes races,...
lotteries and similar activities, and it is prohibited from doing so
whether in "collaboration, association or joint venture" with others or
"by itself." The reason for this is that these are competing activities and
the PCSO should not invest in the business of a... competitor.
When parsed, it will be seen that §1 grants the PCSO authority to do
any of the following: (1) to hold or conduct charity sweepstakes races,
lotteries ands similar activities; and/or (2) to invest - whether "by itself
or in collaboration,... association or joint venture with any person,
association, company or entity" - in any "health and welfare-related
 investments, programs, projects and activities which may be profit
oriented," except "the activities mentioned in the preceding paragraph
(A)," i.e.,... sweepstakes races, lotteries and similar activities. The PCSO
is prohibited from investing in "activities mentioned in the preceding
paragraph (A)" because, as already stated, these are competing
activities.
For the foregoing reasons, we hold:
(1) that petitioners have neither standing to bring this suit nor
substantial interest to make them real parties in interest within the
meaning of Rule 3, §2;
(2) that a determination of the petitioners' right to bring this suit is not
precluded or barred by the decision in the prior case between the
parties;
(3) that the Equipment Lease Agreement of January 25, 1995 is valid as
a lease contract under the Civil Code and is not contrary to the charter
of the Philippine Charity Sweepstakes Office;
(4) that under §1(A) of its charter (R.A. 1169), the Philippine Charity
Sweepstakes Office has authority to enter into a contract for the
holding of an on-line lottery, whether alone or in association,
collaboration or joint venture with another party, so long as it... itself
holds or conducts such lottery; and
(5) That the Equipment Lease Agreement in question did not have to
be submitted to public bidding as a condition for its validity.
WHEREFORE, the Petition for Prohibition, Review and/or Injunction
seeking to declare the Equipment Lease Agreement between the
Philippine Charity Sweepstakes Office and the Philippine Gaming
Management Corp. invalid is DISMISSED.

CASE NO. 12

Manila Prince Hotel Vs GSIS

FACTS
GSIS, pursuant to the privatization program of the government,
decided to sell through public bidding 30% to 51% of the issued
and outstanding shares of MHC. The highest bidder was Renong
Berhard, a Malaysian firm, which bid the 51% shares at P44.00
per share.

Petitioner comes to this Court on prohibition and mandamus, and

invokes Sec. 10, second par., Art. XII of the 1987 Constitution
(Filipino First Policy) and submits that the Manila Hotel has been
identified with the Filipino nation and that the hotel business is
 part of the national economy. Thus, any transaction involving
51% of the shares of stock of the MFC is covered under the
Constitutional provision mentioned above. Also, since its business
is part of the national economy, petitioner should be preferred
after it has matched the bid offer of the Malaysian firm.

Respondents oppose that the provision is not self-executing but

requires an implementing legislation for its enforcement.

ISSUES Whether or not the Filipino First Policy enshrined under the
Constitution is self-executing
RULING
YES, Sec. 10, second par., Art. XII of the 1987 Constitution is self-
executing. It is a mandatory, positive command which is complete
in itself and which needs no further guidelines or implementing
laws or rules for its enforcement. From its very words the
provision does not require any legislation to put it in operation. It
is per se judicially enforceable.

When our Constitution mandates that in the grant of rights,

privileges, and concessions covering national economy and
patrimony, the State shall give preference to qualified Filipinos, it
means just that — qualified Filipinos shall be preferred.

A provision which lays down a general principle, such as those

found in Art. II of the 1987 Constitution, is usually not self-
executing. It commands the legislature to enact laws and carry
out the purposes of the framers. But a provision which is
complete in itself and becomes operative without the aid of
supplementary or enabling legislation, or that which supplies
sufficient rule by means of which the right it grants may be
enjoyed or protected, is self-executing.

Thus, a constitutional provision is self-executing if the nature and

extent of the right conferred and the liability imposed are fixed by
the constitution itself, so that they can be determined by an
examination and construction of its terms, and there is no
language indicating that the subject is referred to the legislature
for action.

In self-executing constitutional provisions, the legislature is not

precluded from enacting further laws to enforce the
constitutional provision so long as the contemplated statute
 squares with the Constitution. The rule is that a self-executing
provision of the constitution does not necessarily exhaust
legislative power on the subject, but any legislation must be in
harmony with the Constitution, further the exercise of
constitutional right and make it more available.

CASE NO. 13

Pamatong v. COMELEC, G.R. No. 161872, April 13, 2004

FACTS When the petitioner, Rev. Elly Velez Pamatong, filed his
Certificate of Candidacy for Presidency, the Commision on
Elections (COMELEC) refused to give the petition its due course.
Pamatong requested a case for reconsideration.
However, the COMELEC again denied his request. The COMELEC
declared Pamatong, along with 35 other people, as
nuisance candidates, as stated in the Omnibus Election Code. The
COMELEC noted that such candidates “could not
wage a nationwide campaign and/or are either not nominated by
a political party or not supported by a registered
political party with national constituency.” Pamatong argued that
this was against his right to “equal access to
opportunities for public service,” citing Article 2, Section 26 of the
Constitution, and that the COMELEC was indirectly
amending the Constitution in this manner. Pamatong also stated
that he is the “most qualified among all the
presidential candidates” and supported the statement with his
legal qualifications, his alleged capacity to wage
national and international campaigns, and his government
platform
ISSUE Whether or not COMELEC’s refusal of Pamatong’s request for
presidential candidacy, along with the grounds for such
refusal, violate the right to equal access to opportunities for
public service.
RULING No. The Court noted that the provisions under Article II are
generally considered not-self executing. As such, the
provision in section 26, along with the other policies in the
article, does not convey any judicially enforceable rights.
Article 2 “merely specifies a guideline for legislative or executive
action” by presenting ideals/standards through the
policies presented. Article 2, Section 26 recognizes a privilege to
 run for public office, one that is subject to limitations
provided by law. As long as these limitations are enforced
without discrimination, then the equal access clause is not
violated. The Court justified the COMELEC’s need for limitations
on electoral candidates given the interest of ensuring
rational, objective, and orderly elections. In the absence of any
limitations, the election process becomes a “mockery”
if anyone, including those who are clearly unqualified to hold a
government position, is allowed to run.
Note: Pamatong presented other evidence that he claims makes
him eligible for candidacy. The Court however stated
that it is not within their power to make such assessments. The
COMELEC case was remanded to COMELEC for
reception of further evidence to determine whether Pamatong is
a nuisance candidate.

CASE NO. 14

Arroyo vs De Venecia G.R. No. 127255 August 14, 1997

FACTS This is a petition for certiorari challenging the validity of RA

8242 (Tax Reform Act) for being passed despite violations of the
internal rules of the House of Representatives (HOR). Petitioners,
members of the HOR, brought this suit against respondents De
Venecia (speaker of the House), et al, on the ground that R.A. No.
8240 is null and void because it was passed in violation of the
rules of the House; that these rules embody the "constitutional
mandate" in Art. VI, Section 16(3) that "each House may
determine the rules of its proceedings" and that, consequently,
violation of the House rules is a violation of the Constitution
itself. Petitioners alleged that during the proceedings, he was
effectively prevented from questioning the presence of a quorum
and that the session was hastily adjourned, and the bill certified
by Speaker De Venecia to prevent petitioner from formally
challenging the existence of a quorum and asking for a
reconsideration. Respondents' defense is anchored on the
principle of separation of powers and the enrolled bill doctrine.
They argued that enforcement of the rules cannot be sought in
the courts except insofar as they implement constitutional
requirements such as that relating to three readings on separate
days before a bill may be passed.
ISSUES Whether or not the Congress committed a grave abuse of
discretion in enacting R.A. No. 8240.
RULING NO. In this case, no rights of private individuals are involved but
 only those of a member who, instead of seeking redress in the
House, chose to transfer the dispute to this Court. We have no
more power to look into the internal proceedings of a House than
members of that House have to look over our shoulders, as long
as no violation of constitutional provisions is shown.

Petitioners must realize that each of the three departments of

our government has its separate sphere which the others may
not invade without upsetting the delicate balance on which our
constitutional order rests. Due regard for the working of our
system of government, more than mere comity, compels
reluctance on our part to enter upon an inquiry into an alleged
violation of the rules of the House.

We must accordingly decline the invitation to exercise our

power. 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. WHEREFORE, the petition for certiorari and prohibition is
DISMISSED.

CASE NO. 15