Facts: House Bill No. 9266, a bill of local application filed in the House of Representatives, was passed on third reading without amendments. But when the bill was discussed in the Senate, substantial amendments were introduced by Senator Tolentino. Those amendments were approved in toto by the Senate. There was also an amendment recommended by Senator Roxas but this does not appear in the journal of the Senate proceedings as having been acted upon. The House of Representatives thereafter signified its approval of H.B.9266 containing the amendments recommended by Senator Roxas and not the Tolentino amendments which were the ones actually approved by the Senate. The printed copies of the bill were then certified and attested by the Secretary of the House of Representatives, the Speaker of the House of Representatives, the Secretary of the Senate and the Senate President. Then the President affixed his signature thereto by way of approval. The bill became RA 4065.
Senator Tolentino issued a press statement that the enrolled copy of H.B. 9266 signed into law by the President was a wrong version of the bill actually passed by the Senate because it did not embody the amendments introduced by him and approved on the Senate floor. As a consequence, the Senate President invalidated his signature on the bill. Thereafter, the President withdrew his signature on H.B. 9266.
Issue: Whether or not the enrolled bill doctrine should be adhered to
Held: The enrolled bill theory is based mainly on the respect due to coequal and independent departments, which requires the judicial department to accept, as having passed Congress, all bills authenticated in the right manner.
Petitioner’s argument that the attestation of the presiding officers of Congress is conclusive proof of a bill’s due enactment, required, it is said, by the respect due to a co-equal department of the government, is neutralized by the fact that the Senate President declared his signature on the bill to be invalid and issued a subsequent clarification that the invalidation of his signature meant that the bill he had signed had never been approved by the Senate. Absent such attestation as a result of the disclaimer, and consequently there being no enrolled bill to speak of, the entries in the journal should be consulted.
The journal discloses that substantial and lengthy amendments were introduced on the floor and approved by the Senate but were not incorporated in the printed text sent to the President and signed by him. The Court declares that the bill was not duly enacted and therefore did not become a law.
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