United States vs PonsJuan Pons and Gabino Beliso were trading partners. On April 10, 1915 the steamer Lopez y Lopez arrived in Manila from Spain and it contained 25 barrels of wine. The said barrels of wine were delivered to Beliso. Beliso subsequently delivered 5 barrels to Pons house. On the other hand, the customs authorities noticed that the said 25 barrels listed as wine on record were not delivered to any listed merchant (Beliso not being one). And so the customs officers conducted an investigation thereby discovering that the 25 barrels of wine actually contained 520 tins of opium (amounting to 125 kg of opium valued P62,400). Since the act of trading and dealing opium is against Act No. 2381, Pons and Beliso were charged for illegally and fraudulently importing and introducing such contraband material to the Philippines. Pons appealed the sentence arguing that Act 2381 was approved while the Philippine Commission (Congress) was not in session. He said that his witnesses claim that the said law was passed/approved on 01 March 1914 while the special session of the Commission was adjourned at 12MN on February 28, 1914. Since this is the case, Act 2381 should be null and void.ISSUE: Whether or not the SC must go beyond the recitals of the Journals to determine if Act 2381 was indeed made a law on February 28, 1914.HELD: Act No. 1679 provides the Sec of the Commission to perform duties required of the recorder of commission under the existing law.Rules 15 & 16 provides that proceedings of the commission shall be briefly and accurately stated in the journal.Therefore, the Philippine Assembly must keep a journal of its proceedings which then should be published. And it appears in the journal that Act 2381 was signed on February 28, 1914 when the assembly adjourned.Section 275 of Code of Civil Procedure provides that official acts of legislative, executive and judiciary shall be judicially recognized by the court w/o introduction of proof, may receive subjects to which they may resort to find aid, through appropriate documents, books or evidence.The SC looked into the Journals to ascertain the date of adjournment but the SC refused to go beyond the recitals in the legislative Journals. The said Journals are conclusive on the Court and to inquire into the veracity of the journals of the Philippine Legislature, when they are, as the SC have said, clear and explicit, would be to violate both the letter and the spirit of the organic laws by which the Philippine Government was brought into existence, to invade a coordinate and independent department of the Government, and to interfere with the legitimate powers and functions of the Legislature. Pons witnesses cannot be given due weight against the conclusiveness of the Journals which is an act of the legislature. The journals say that the Legislature adjourned at 12 midnight on February 28, 1914. This settles the question, and the court did not err in declining to go beyond these journals. The SC passed upon the conclusiveness of the enrolled bill in this particular case.CASCO Philippine Chemical Co. vs GimenezFACTS:On July 1, 1959, pursuant to Republic Act No. 2609 (Foreign Exchange margin Fee Law), the Central Bank of the Philippines fixed a uniform margin fee of 25% foreign exchange transactions. Petitioner Casco Philippine Chemical Co., Inc., a manufacturer of resin glues, had bought foreign exchange for the importation of urea and formaldehyde raw materials for the said glues and were thus paying for the margin fees required.Relying upon Resolution No. 1529 of the Monetary Board of the said bank declaring that the separate importation of urea and formaldehyde is exempt from the said fee, the petitioner sought for a refund of the margin fees that had been paid. This was denied by the Auditor of the said Bank stating that the claim was not in accord with the provisions of section 2, paragraph XVIII of R.A. 2609.ISSUE: Whether urea and formaldehyde are exempt by law from the payment of the aforesaid margin feeHELD/RULING:Urea and formaldehyde is not exempt from law.The pertinent portion of Section 2 of Republic Act No. 2609 reads:The margin established by the Monetary Board pursuant to the provision of section one hereof shall not be imposed upon the sale of foreign exchange for the importation of the following:x x x x x x x x xXVIII. Urea formaldehyde for the manufacture of plywood and hardboard when imported by and for the exclusive use of end-users. (Emphasis provided.)Urea formaldehyde is different from urea and formaldehyde, the former being a finished product. It is well settled that the enrolled bill which uses the term urea formaldehyde instead of urea and formaldehyde is conclusive upon the courts as regards the tenor of the measure passed by Congress and approved by the President. The courts cannot speculate that there had been an error in the printing of the bill as this shall violate the principle of separation of powers. Shall there have been any error in the printing, the remedy is by amendment or curative legislation, not by judicial decree.Astorga vs VillegasIn 1964, Antonio Villegas (then Mayor of Manila) issued circulars to the department heads and chiefs of offices of the city government as well as to the owners, operators and/or managers of business establishments in Manila to disregard the provisions of Republic Act No. 4065. He likewise issued an order to the Chief of Police to recall five members of the city police force who had been assigned to then Vice-Mayor Herminio Astorga (assigned under authority of RA 4065).Astorga reacted against the steps carried out by Villegas. He then filed a petition for Mandamus, Injunction and/or Prohibition with Preliminary Mandatory and Prohibitory Injunction to compel Villegas et al and the members of the municipal board to comply with the provisions of RA 4065 (filed with the SC). In his defense, Villegas denied recognition of RA 4065 (An Act Defining the Powers, Rights and Duties of the Vice-Mayor of the City of Manila) because the said law was considered to have never been enacted. When the this said law passed the 3rd reading in the lower house as House Bill No. 9266, it was sent to the Senate which referred it to the Committee on Provinces and Municipal Governments and Cities headed by then Senator Roxas. Some minor amendments were made before the bill was referred back to the Senate floor for deliberations. During such deliberations, Sen. Tolentino made significant amendments which were subsequently approved by the Senate. The bill was then sent back to the lower house and was thereafter approved by the latter. The bill was sent to the President for approval and it became RA 4065. It was later found out however that the copy signed by the Senate President, sent to the lower house for approval and sent to the President for signing was the wrong version. It was in fact the version that had no amendments thereto. It was not the version as amended by Tolentino and as validly approved by the Senate. Due to this fact, the Senate president and the President of the Philippines withdrew and invalidated their signatures that they affixed on the said law.Astorga maintains that the RA is still valid and binding and that the withdrawal of the concerned signatures does not invalidate the statute. Astorga further maintains that the attestation of the presiding officers of Congress is conclusive proof of a bills due enactment.ISSUE: Whether or not RA 4065 was validly enacted.HELD: No. The journal of the proceedings of each House of Congress is no ordinary record. The Constitution requires it. While it is true that the journal is not authenticated and is subject to the risks of misprinting and other errors, the journal can be looked upon in this case. The SC is merely asked to inquire whether the text of House Bill No. 9266 signed by the President was the same text passed by both Houses of Congress. Under the specific facts and circumstances of this case, the SC can do this and resort to the Senate journal for the purpose. 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. Note however that the SC is not asked to incorporate such amendments into the alleged law but only to declare that the bill was not duly enacted and therefore did not become law. As done by both the President of the Senate and the Chief Executive, when they withdrew their signatures therein, the SC also declares that the bill intended to be as it is supposed to be was never made into law. To perpetuate that error by disregarding such rectification and holding that the erroneous bill has become law would be to sacrifice truth to fiction and bring about mischievous consequences not intended by the law-making body.PHILIPPINES JUDGES ASSOCIATION v. PRADOFACTS:Petitioners assailed the validity of Sec 35 R.A. No. 7354 which withdraw the franking privilege from the Supreme Court, the Court of Appeals, the Regional Trial Courts, the Metropolitan Trial Courts, the Municipal Trial Courts, and the Land Registration Commission and its Registers of Deeds, along with certain other government offices.The petition assails the constitutionality of R.A. No. 7354 on the grounds that: (1) its title embraces more than one subject and does not express its purposes; (2) it did not pass the required readings in both Houses of Congress and printed copies of the bill in its final form were not distributed among the members before its passage; and (3) it is discriminatory and encroaches on the independence of the Judiciary.ISSUE:Whether or not Sec 35 of RA 7354 is constitutional.

RULING:No. SC held that Sec 35 R.A. No. 7354 is unconstitutional.1. Article VI, Sec. 26(l), of the Constitution providing that "Every bill passed by the Congress shall embrace only one subject which shall be expressed in the title thereof."The title of the bill is not required to be an index to the body of the act, or to be as comprehensive as to cover every single detail of the measure. It has been held that if the title fairly indicates the general subject, and reasonably covers all the provisions of the act, and is not calculated to mislead the legislature or the people, there is sufficient compliance with the constitutional requirement.We are convinced that the withdrawal of the franking privilege from some agencies is germane to the accomplishment of the principal objective of R.A. No. 7354, which is the creation of a more efficient and effective postal service system. Our ruling is that, by virtue of its nature as a repealing clause, Section 35 did not have to be expressly included in the title of the said law.2. The petitioners maintain that the second paragraph of Sec. 35 covering the repeal of the franking privilege from the petitioners and this Court under E.O. 207, PD 1882 and PD 26 was not included in the original version of Senate Bill No. 720 or House Bill No. 4200. As this paragraph appeared only in the Conference Committee Report, its addition, violates Article VI, Sec. 26(2) of the Constitution. The petitioners also invoke Sec. 74 of the Rules of the House of Representatives, requiring that amendment to any bill when the House and the Senate shall have differences thereon may be settled by a conference committee of both chambers.Casco Philippine Chemical Co. v. Gimenez laid down the rule that the enrolled bill, is conclusive upon the Judiciary (except in matters that have to be entered in the journals like the yeas and nays on the final reading of the bill). The journals are themselves also binding on the Supreme Court.Applying these principles, we shall decline to look into the petitioners' charges that an amendment was made upon the last reading of the bill that eventually became R.A. No. 7354 and that copies thereof in its final form were not distributed among the members of each House. Both the enrolled bill and the legislative journals certify that the measure was duly enacted i.e., in accordance with Article VI, Sec. 26(2) of the Constitution. We are bound by such official assurances from a coordinate department of the government, to which we owe, at the very least, a becoming courtesy.3. SC annuls Section 35 of the law as violative of Article 3, Sec. 1, of the Constitution providing that no person shall "be deprived of the equal protection of laws."It is worth observing that the Philippine Postal Corporation, as a government-controlled corporation, was created and is expected to operate for the purpose of promoting the public service. While it may have been established primarily for private gain, it cannot excuse itself from performing certain functions for the benefit of the public in exchange for the franchise extended to it by the government and the many advantages it enjoys under its charter. 14 Among the services it should be prepared to extend is free carriage of mail for certain offices of the government that need the franking privilege in the discharge of their own public functions. Vera vs AvelinoFACTSIt was stated in the report submitted concerning the national elections, that certain acts of terrorism and violence were recorded in provinces of Pampanga, Nueva Ecija, Bulacan and Tarlac and the voting in the said region does not reflect thetrue expression of the popular will. (They were coerced or intimidated to vote for the candidate that these lawless elements are vying for)A resolution was approved referring to the said report, which orders the termination of protest against the election of Jose Vera, Ramon Diokno and Jose Romero (who was included to those who received the highest number of votes), which hinders them from taking oath and be seated in the Congress. These protest were filed in the electoral tribunal of the Senate of the PhilippinesThe petitioners prayed for an order to annul the said resolution and to permit them to occupy their seats. The court ruled that they have no jurisdiction over the said case, as decided in Alejandrino vs Quezon. The court cannot decide or impel the legislative in actions/decisions that are purely legislative in character, which pertains to their functions where they have the exclusive control. They cannot do so without usurping the power of their co-equal branch (which is unconstitutional , by virtue of separation of powers). This includes the decisions of expelling a member of the House, whether it was right or wrong. [Hands-off policy]The court asserted the validity of Pendatun Resolution Vera vs Avelino Case Digest

FACTS:Commission on Elections submitted last May 1946 to the President and the Congress of the Philippines a report regarding the national elections held the previous month. It stated that by reason of certain specified acts of terrorism and violence in the province of Pampanga, Nueva Ecija, Bulacan and Tarlac, the voting in said region did not reflect the true and free expression of the popular will.During the session, when the senate convened on May 25, 1946, a pendatum resolution was approved referring to the report ordering that Jose O. Vera, Ramon Diokno and Jose E. Romero who had been included among the 16 candidates for senator receiving the highest number of votes, proclaimed by the Commissions on Elections shall not be sworn, nor seated, as members of the chamber, pending the termination of the of the protest lodged against their election.Petitioners thus immediately instituted an action against their colleagues responsible for the resolution, praying for an order to annul it and compelling respondents to permit them to occupy their seats and to exercise their senatorial prerogative. They also allege that only the Electoral Tribunal had jurisdiction over contests relating to their election, returns and qualifications. Respondents assert the validity of the pendatun resolution.

ISSUES:1.Whether the Commission on Elections has the jurisdiction to determine whether or not votes cast in the said provinces are valid.2.Whether administration of oath and the sitting of Jose O. Vera, Ramon Diokno and Jose Romero should be deferred pending hearing and decision on the protests lodged against their elections.

RULING:The Supreme Court refused to intervene, under the concept of separation of powers, holding that the case was not a contest, and affirmed the inherent right of the legislature to determine who shall be admitted to its membership.Case dismissed.

Abbas vs SETIn October 1987, Firdausi Abbas et al filed before the SET an election contest against 22 candidates of the LABAN coalition who were proclaimed senators-elect in the May 11 (1987) congressional elections by the COMELEC. The SET was at the time composed of three (3) Justices of the Supreme Court and six (6) Senators. Abbas later on filed for the disqualification of the 6 senator members from partaking in the said election protest on the ground that all of them are interested parties to said case. Abbas argue that considerations of public policy and the norms of fair play and due process imperatively require the mass disqualification sought. To accommodate the proposed disqualification, Abbas suggested the following amendment: Tribunals Rules (Section 24) - requiring the concurrence of five (5) members for the adoption of resolutions of whatever nature - is a proviso that where more than four (4) members are disqualified, the remaining members shall constitute a quorum, if not less than three (3) including one (1) Justice, and may adopt resolutions by majority vote with no abstentions. Obviously tailored to fit the situation created by the petition for disqualification, this would, in the context of that situation, leave the resolution of the contest to the only three Members who would remain, all Justices of this Court, whose disqualification is not sought.

ISSUE: Whether or not Abbas proposal could be given due weight.

HELD: The most fundamental objection to such proposal lies in the plain terms and intent of the Constitution itself which, in its Article VI, Section 17, creates the Senate Electoral Tribunal, ordains its composition and defines its jurisdiction and powers.

Sec. 17. The Senate and the House of Representatives shall each have an Electoral Tribunal which shall be the sole judge of all contests relating to the election, returns, and qualifications of their respective Members. Each Electoral Tribunal shall be composed of nine Members, three of whom shall be Justices of the Supreme Court to be designated by the Chief Justice, and the remaining six shall be Members of the Senate or the House of Representatives, as the case may be, who shall be chosen on the basis of proportional representation from the political parties and the parties or organizations registered under the party-list system represented therein. The senior Justice in the Electoral Tribunal shall be its Chairman.

It is quite clear that in providing for a SET to be staffed by both Justices of the SC and Members of the Senate, the Constitution intended that both those judicial and legislative components commonly share the duty and authority of deciding all contests relating to the election, returns and qualifications of Senators. The legislative component herein cannot be totally excluded from participation in the resolution of senatorial election contests, without doing violence to the spirit and intent of the Constitution. It is not to be misunderstood in saying that no Senator-Member of the SET may inhibit or disqualify himself from sitting in judgment on any case before said Tribunal. Every Member of the Tribunal may, as his conscience dictates, refrain from participating in the resolution of a case where he sincerely feels that his personal interests or biases would stand in the way of an objective and impartial judgment. What SC is saying is that in the light of the Constitution, the SET cannot legally function as such; absent its entire membership of Senators and that no amendment of its Rules can confer on the three Justices-Members alone the power of valid adjudication of a senatorial election contest.BONDOC VS PINEDAIn the elections held on May 11, 1987,Marciano Pineda of the LDP and Emigdio Bondoc of the NP were candidates for the position of Representative for the Fourth District of Pampanga. Pineda was proclaimed winner. Bondoc filed a protest in the House of Representatives Electoral Tribunal (HRET), which is composed of 9 members, 3 of whom are Justices of the SC and the remaining 6 are members of the House of Representatives (5members belong to the LDP and 1 member is from the NP). Thereafter, a decision had been reached in which Bondoc won over Pineda. Congressman Camasura of the LDP voted with the SC Justices and Congressman Cerilles of the NP to proclaim Bondoc the winner of the contest. On the eve of the promulgation of the Bondoc decision, Congressman Camasura received a letter informing him that he was already expelled from the LDP for allegedly helping to organize the Partido Pilipino of Eduardo Cojuangco and for allegedly inviting LDP members in Davao Del Sur to join said political party. On the day of the promulgation of the decision, the Chairman of HRET received a letter informing the Tribunal that on the basis of the letter from the LDP, the House of Representatives decided to withdraw the nomination and rescind the election of Congressman Camasura to the HRET.Issue: Whether or not the House of Representatives, at the request of the dominant political party therein, may change that partys representation in the HRET to thwart the promulgation of a decision freely reached by the tribunal in an election contest pending therein Held: The purpose of the constitutional convention creating the Electoral Commission was to provide an independent and impartial tribunal for the determination of contests to legislative office, devoid of partisan consideration. As judges, the members of the tribunal must be non-partisan. They must discharge their functions with complete detachment, impartiality and independence even independence from the political party to which they belong. Hence, disloyalty to party and breach of party discipline are not valid grounds for the expulsion of a member of the tribunal. In expelling Congressman Camasura from the HRET for having cast a conscience vote in favor of Bondoc, based strictly on the result of the examination and appreciation of the ballots and the recount of the votes by the tribunal, the House of Representatives committed a grave abuse of discretion, an injustice and a violation of the Constitution. Its resolution of expulsion against Congressman Camasura is, therefore, null and void. Another reason for the nullity of the expulsion resolution of the House of Representatives is thatit violates Congressman Camasuras right to security of tenure. Members of the HRET, as sole judge of congressional election contests, are entitled to security of tenure just as members of the Judiciary enjoy security of tenure under the Constitution. Therefore, membership in the HRET may not be terminated except for a just cause, such as, the expiration of the members congressional term of office, his death, permanent disability, resignation from the political party he represents in the tribunal, formal affiliation with another political party or removal for other valid cause. A member may