Morales v.

Subido, 27 SCRA 131 (1969)

Facts: The petitioner Enrique V. Morales was the chief of the detective bureau of the Manila
Police Department. He was designated as acting chief of police of Manila when the former
chief resigned. He was also appointed to the same position by the Mayor of Manila. The
respondent Abelardo Subido, commissioner of the civil service, approved the designation of
the petitioner as acting chief but rejected his permanent appointment for “failure to meet
the minimum educational and civil service eligibility requirements for the said position” and
instead certified other persons as qualified for the position to be filled. Subido cited section
10 of the Police Act of 1966 (RA 4864), which provided the minimum qualifications for
appointment as chief of a city police agency. Morales asserted that there were various
changes made in House Bill 6951, now RA 4864, during the legislative process, and that the
version approved by the Senate on third reading was different from the enrolled bill that
was signed by the President. Morales submitted certified photostatic copies of the different
drafts of the bill as evidence. Under the version he presented, he was qualified for the
position, being a high school graduate who had served the city’s police department for at
least eight years with the rank of captain and/or higher.

Issue: Whether or not the enrolled bill doctrine should apply in this case.

Ruling: The Supreme Court dismissed the petition and held that the enrolled bill doctrine
should apply. The Court applied the principle that the text of the act as passed and
approved is deemed importing absolute verity and is binding on the courts. The Court also
cited the constitutional provision that requires the signing of a bill by the Speaker of the
House and the Senate President and the certification of the Secretaries of both Houses of
Congress that it was passed as conclusive as to its due enactment. The Court said that the
enrolled bill is the official and authentic evidence of the act of the legislature, and that the
courts cannot go behind the enrolled bill to determine what really passed in Congress. The
Court also noted that the petitioner failed to show any clear and conclusive proof that the
enrolled bill was not the same as the bill actually passed by Congress.

NOTES:

 The case is an example of the application of the enrolled bill doctrine, which is a rule
of statutory construction that gives preference to the enrolled bill over the journal or
any other evidence in case of conflict. The doctrine is based on the principle of
separation of powers and the respect due to the co-equal branches of government.

 The case also illustrates the importance of the constitutional requirement that the
bills passed by Congress be signed by the presiding officers of both Houses and
certified by the respective secretaries. This requirement ensures that the bills are
properly authenticated and verified before they are presented to the President for
approval or veto.

 The case also shows the difference between an enrolled bill and a journal. An
enrolled bill is the final copy of the bill that is signed by the President and becomes a
law. A journal is the official record of the proceedings and actions of the legislature
on a bill.