ARTURO M. TOLENTINO, vs. THE SECRETARY OF FINANCE and THE COMMISSIONER OF INTERNAL REVENUE.
- G.R. Number: G.R. No. 115455
- Promulgated: 1994-08-25
- Ponente: Mendoza, J.
Doctrine
Judicial power includes the duty to determine whether there has been a grave abuse of discretion amounting to lack or excess of jurisdiction by any branch or instrumentality of government.
The enrolled-bill rule generally precludes courts from going behind the enrolled act to examine legislative procedure, except for matters the Constitution expressly requires be entered in the journals.
A statute's title need not be a complete index of its content; an amendment (e.g., widening the VAT base) is fairly embraced if the title reasonably describes the statute's purpose.
Facts
Republic Act No. 7716 amended the National Internal Revenue Code to widen the VAT base and enhance its administration, imposing a 10% VAT on sales and services (EVAT law).
Multiple petitions for certiorari and prohibition challenged the constitutionality and legislative procedure in the enactment of R.A. No. 7716; the issues were consolidated as summarized by the Court.
Petitioners alleged procedural defects in the conference committee's consolidation of House and Senate bills, including insertion of provisions and closed-door meetings.
The Court considered claims regarding the enrolled-bill doctrine, journal entries, and whether judicial inquiry into legislative procedures is permissible.
Issues
Whether Republic Act No. 7716 is constitutional in its formal and substantive aspects.
Whether courts may judicially inquire into alleged procedural violations in Congress beyond constitutional requirements (i.e., whether such inquiry is precluded by separation of powers).
Whether the enrolled-bill doctrine conclusively bars judicial review of alleged procedural irregularities in the passage of R.A. No. 7716.
Ruling
The Court dismissed the petitions and upheld R.A. No. 7716; petitions in these cases are DISMISSED.
The Court held that judicial inquiry into formal requirements for enactment of statutes beyond those prescribed by the Constitution is precluded by the separation of powers.
The enrolled bill doctrine retains force: the enrolled act is conclusive in many respects, so courts generally may not go behind the enrolled bill to impeach procedural regularity except as expressly required by the Constitution.
Keywords
G.R. No. 115455, Republic Act No. 7716, Expanded Value-Added Tax Law, Value-Added Tax (VAT), Constitution Art. VI, § 24, Constitution Art. VI, § 26(2), certiorari and prohibition, constitutionality, National Internal Revenue Code, revenue or tariff bills, Bicameral Conference Committee, legislative process, originate exclusively in the House of Representatives, three readings on separate days, Bill of Rights (Art. III), self-executing constitutional provisions, judicial cognizance, House Ways and Means Committee, Senate Committee on Ways and Means, august