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Also, the matters contained in the following were written in accordance with the law, rules, and jurisprudence prevailing at the time of writing and posting, and do not include any future developments on the subject matter under discussion.
AT A GLANCE:
The rationale behind the enrolled bill doctrine rests on the consideration that the respect due to coequal and independent departments requires the Judiciary to act upon that assurance, and to accept, as having passed Congress, all bills authenticated in the manner stated; leaving the court to determine, when the question properly arises, whether the Act, so authenticated, is in conformity with the Constitution.
What is the Enrolled Bill Doctrine?
The case of Council of Teachers and Staff of Colleges and Universities of the Philippines v. Secretary of Education, G.R. Nos. 216930, October 09, 2018 is instructive that under the enrolled bill doctrine, 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 is conclusive not only as to its provisions but also as to its due enactment.
Rationale
In the same case, it was held that the rationale behind the enrolled bill doctrine rests on the consideration that the respect due to coequal and independent departments requires the Judiciary to act upon that assurance, and to accept, as having passed Congress, all bills authenticated in the manner stated; leaving the court to determine, when the question properly arises, whether the Act, so authenticated, is in conformity with the Constitution.
Consistent Adherence
Jurisprudence will show that the Court has consistently adhered to the enrolled bill doctrine. Claims that the required three-fourths vote for constitutional amendment has not been obtained, that irregularities attended the passage of the law, that the tenor of the bill approved in Congress was different from that signed by the President, that an amendment was made upon the last reading of the bill, and even claims that the enrolled copy of the bill sent to the President contained provisions which had been surreptitiously inserted by the conference committee, had all failed to convince the Court to look beyond the four corners of the enrolled copy of the bill. (Council of Teachers and Staff of Colleges and Universities of the Philippines v. Secretary of Education)
Moreover, in Joker P. Arroyo, et. al. v. Jose De Venecia, et. al, G.R. No. 127255, August 14, 1997, the Supreme Court has refused to even look into allegations that the enrolled bill sent to the President contained provisions which had been “surreptitiously” inserted in the conference committee. The Court stated that where allegations that the constitutional procedures for the passage of bills have not been observed have no more basis than another allegation that the Conference Committee “surreptitiously” inserted provisions into a bill which it had prepared, we should decline the invitation to go behind the enrolled copy of the bill. To disregard the “enrolled bill” rule in such cases would be to disregard the respect due the other two departments of our government.
Likewise, the Court in said case refused to look into charges that an amendment was made upon the last reading of a bill in violation of Article. VI, Section 26(2) of the Constitution that upon the last reading of a bill, no amendment shall be allowed.
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