This case involved a petition challenging the constitutionality of a congressional resolution proposing a constitutional amendment. Petitioners argued their votes were not properly counted, meaning the resolution did not receive the required supermajority. The Supreme Court dismissed the petition, adopting the enrolled bill theory. This means that a duly authenticated legislative enactment, like the enrolled resolution, is conclusively presumed valid. The Court will not look behind an enrolled bill and investigate legislative journals, as that undermines separation of powers. The enrolled resolution was binding proof of its own contents and valid enactment.
This case involved a petition challenging the constitutionality of a congressional resolution proposing a constitutional amendment. Petitioners argued their votes were not properly counted, meaning the resolution did not receive the required supermajority. The Supreme Court dismissed the petition, adopting the enrolled bill theory. This means that a duly authenticated legislative enactment, like the enrolled resolution, is conclusively presumed valid. The Court will not look behind an enrolled bill and investigate legislative journals, as that undermines separation of powers. The enrolled resolution was binding proof of its own contents and valid enactment.
This case involved a petition challenging the constitutionality of a congressional resolution proposing a constitutional amendment. Petitioners argued their votes were not properly counted, meaning the resolution did not receive the required supermajority. The Supreme Court dismissed the petition, adopting the enrolled bill theory. This means that a duly authenticated legislative enactment, like the enrolled resolution, is conclusively presumed valid. The Court will not look behind an enrolled bill and investigate legislative journals, as that undermines separation of powers. The enrolled resolution was binding proof of its own contents and valid enactment.
This case involved a petition challenging the constitutionality of a congressional resolution proposing a constitutional amendment. Petitioners argued their votes were not properly counted, meaning the resolution did not receive the required supermajority. The Supreme Court dismissed the petition, adopting the enrolled bill theory. This means that a duly authenticated legislative enactment, like the enrolled resolution, is conclusively presumed valid. The Court will not look behind an enrolled bill and investigate legislative journals, as that undermines separation of powers. The enrolled resolution was binding proof of its own contents and valid enactment.
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Mabanag vs Lopez Vito
FACTS This is a petition for prohibition to prevent the enforcement of a congressional resolution designated "Resolution of both houses proposing an amendment to the Constitution of the Philippines to be appended as an ordinance thereto." The petitioners contend that their vote were not taken into consideration in requiring that in amending the constitution, the law requires 3/4 of the votes of the member of the Congress thus arriving in the question of constitutionality of the said resolution. ISSUES Whether or not the Court has jurisdiction and whether or not the journals can be investigated against the conclusiveness of the enrolled bills. HELD Petition is dismissed without cost. The Court held that to go behind the enrolled bills which were already authenticated and to investigate the journals amounts to disregard of the respect due to the coequal and independent department of the state, and it would be an inquisition into the conduct of the members of the legislature, a very delicate power, the frequent exercise of which must lead to confusion in the administration of the law. Duly certified copies shall be conclusive proof of the provisions of Acts and the due enactment thereof.
G.R. No. L-1123: Mabanag vs Lopez Vito Journal Adoption of the Enrolled Bill Theory
FACTS: Petitioners include 3 senators and 8 representatives. The three senators were suspended by senate due to election irregularities. The 8 representatives were not allowed to take their seat in the lower House except in the election of the House Speaker. They argued that some senators and House Reps were not considered in determining the required vote (of each house) in order to pass the Resolution (proposing amendments to the Constitution) which has been considered as an enrolled bill by then. At the same time, the votes were already entered into the Journals of the respective House. As a result, the Resolution was passed but it could have been otherwise were they allowed to vote. If these members of Congress had been counted, the affirmative votes in favor of the proposed amendment would have been short of the necessary three-fourths vote in either branch of Congress. Petitioners filed or the prohibition of the furtherance of the said resolution amending the constitution. Respondents argued that the SC cannot take cognizance of the case because the Court is bound by the conclusiveness of the enrolled bill or resolution.
ISSUE: Whether or not the Court can take cognizance of the issue at bar. Whether or not they said resolution was duly enacted by Congress
HELD: As far as looking into the Journals is concerned, even if both the journals from each House and an authenticated copy of the Act had been presented, the disposal of the issue by the Court on the basis of the journals does not imply rejection of the enrollment theory, for, as already stated, the due enactment of a law may be proved in either of the two ways specified in section 313 of Act No. 190 as amended. The SC found in the journals no signs of irregularity in the passage of the law and did not bother itself with considering the effects of an authenticated copy if one had been introduced. It did not do what the opponents of the rule of conclusiveness advocate, namely, look into the journals behind the enrolled copy in order to determine the correctness of the latter, and rule such copy out if the two, the journals and the copy, be found in conflict with each other. No discrepancy appears to have been noted between the two documents and the court did not say or so much as give to understand that if discrepancy existed it would give greater weight to the journals, disregarding the explicit provision that duly certified copies "shall be conclusive proof of the provisions of such Acts and of the due enactment thereof."
**Enrolled Bill that which has been duly introduced, finally passed by both houses, signed by the proper officers of each, approved by the president and filed by the secretary of state.
Section 313 of the old Code of Civil Procedure (Act 190), as amended by Act No. 2210, provides: "Official documents may be proved as follows: . . . (2) the proceedings of the Philippine Commission, or of any legislatives body that may be provided for in the Philippine Islands, or of Congress, by the journals of those bodies or of either house thereof, or by published statutes or resolutions, or by copies certified by the clerk of secretary, or printed by their order; Provided, That in the case of Acts of the Philippine Commission or the Philippine Legislature, when there is an existence of a copy signed by the presiding officers and secretaries of said bodies, it shall be conclusive proof of the provisions of such Acts and of the due enactment thereof."
The SC is bound by the contents of a duly authenticated resolution (enrolled bill) by the legislature. In case of conflict, the contents of an enrolled bill shall prevail over those of the journals.
