[go: up one dir, main page]
Scribd
Upload
135 views2 pages

Statutory Construction Case Digest BUCAO

This document summarizes a case, Arroyo vs. De Venecia, which challenged the validity of a law imposing sin taxes on beer and cigarettes. The petitioner claimed the law violated House rules, but the Supreme Court dismissed this, saying courts cannot invalidate laws based on alleged procedural violations. The Court also cited the enrolled bill doctrine - that signed bills are conclusively presumed to be properly enacted, absent evidence to the contrary. The Court ruled there was no grave abuse of discretion by respondents in passing the law.

Uploaded by

Xyrus Bucao
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
135 views2 pages

Statutory Construction Case Digest BUCAO

This document summarizes a case, Arroyo vs. De Venecia, which challenged the validity of a law imposing sin taxes on beer and cigarettes. The petitioner claimed the law violated House rules, but the Supreme Court dismissed this, saying courts cannot invalidate laws based on alleged procedural violations. The Court also cited the enrolled bill doctrine - that signed bills are conclusively presumed to be properly enacted, absent evidence to the contrary. The Court ruled there was no grave abuse of discretion by respondents in passing the law.

Uploaded by

Xyrus Bucao
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
You are on page 1/ 2

Statutory Construction

Case Digest by Bucao, Xyrus Alan R.


EH-204

Arroyo vs. De Venecia, et.al.


GR. No. 127255 June 26, 1998

Facts:
• Petition for Certiorari and Prohibition challenging the validity of RA 8240 amending
certain provision of the NIRC by imposing so called the Sin Tax imposed on the sale of
Beer and Cigarettes

• Petitioner claimed that Respondents violated Rule 8, Sec 35, Rule 17, Sec. 103, Rule 19,
Sec. 112, Rule 16,Sec. 97, Rule 20, Sec. 121-122, Rule 21, Sec. 123 and Rule 18, Sec.
109 of the House Rules (Violation of the House Rules tantamount to violation of the
Constitution)

• Art. 6, Sec. 16

• Art. 6, Sec. 26-27 of the 1987 Constitution

Issue:
• WON there was grave abuse of discretion of the part of the Repsondents in enacting RA
8240?

Ruling
• It is clear from the facts that what was alleged to have been violated in the enactment
of the said RA 8240 are merely internal rules of procedure of the House rather than the
Constitutional Requirement for the enactment of the law, that is Art. 6, Sec. 26-27 of
the 1987 Constitution. Pertaining the existence of Quorum.

• The established rule is that the courts cannot declare an act of legislature void on
account merely of non-compliance with the rules of procedure made by itself.

• It follows that the case at hand does not present a situation in which a branch of the
government has gone beyond the constitutional limit of its jurisdiction so as to call for
the exercise of Art. 8, Sec. 1 (Judicial power of the Supreme Court)

• Moreover, under the enrolled bill doctrine, the signing of House Bill no. 7198 by Speaker
of the house and Senate President and certification of both secretaries of both houses
that was passed are conclusive of its enactment.
• Petition is DISMISSED

Rules on Statutory Construction


• Enrolled Bill and Journals – Extrinsic aids use to determine whether certain provisions of
a statute had been approved.

• Art. 6, Sec. 16

Each House shall keep a journal of its proceedings, and from time to time publish the same ,
expecting such parts as may, in its judgment, affect national security; and yeas and nays on
any question shall, at the request of 1/5 of the members present, entered in the journal.

• Doctrine of Enrolled Bill – conclusive presumption of its legitimate and due enactment.
Absence of evidence to the contrary, the journal is accorded with conclusive effect.

You might also like