Title
Mabanag vs. Vito
Case
G.R. No. L-1123
Decision Date
Mar 5, 1947
A dispute arises over the validity of a resolution proposing a constitutional amendment in the
Philippines, with senators, representatives, and political party presidents arguing against its
validity, while members of Congress defend its enforceability; the court ultimately rules in favor
of the resolution, emphasizing the importance of duly authenticated bills and rejecting the
theory of the enrolled bill.
acts:
In Mabanag v. Vito, petitioners Alejo Mabanag and others sought to prevent the
enforcement of a congressional resolution proposing an amendment to the Philippine
Constitution.
The resolution aimed to grant U.S. citizens and businesses the same rights as Filipinos in
exploiting natural resources and operating public utilities in the Philippines.
Petitioners included eight senators, seventeen representatives, and the presidents of the
Democratic Alliance, the Popular Front, and the Philippine Youth Party.
Respondents were members of the Commission on Elections, the Treasurer of the
Philippines, the Auditor General, and the Director of the Bureau of Printing.
The resolution was adopted on September 18, 1946, with 16 senators voting in favor and
5 against, and 68 representatives voting in favor and 18 against.
Petitioners argued that the resolution did not meet the constitutional requirement of a
three-fourths vote from all members of each house.
They claimed that three senators and eight representatives were unlawfully excluded
from voting, which would have resulted in the resolution failing to achieve the necessary
three-fourths majority.
The case was heard based on pleadings and a stipulation of facts, including the status
and actions of the excluded members.
Issue:
1. Did the exclusion of certain members from the voting process invalidate the
resolution proposing the constitutional amendment?
Whether the exclusion of members affected the validity of the resolution.
2. Does the court have the jurisdiction to review the validity of the resolution
and the legislative process involved?
Whether the judiciary can review the legislative process and resolution.
3. Is the certification of the resolution by the presiding officers of Congress
conclusive and binding on the courts?
Whether the certification by Congress's presiding officers is final and binding.
Ruling:
1. On the exclusion of members: The court ruled that the resolution was valid despite
the exclusion of certain members from the voting process.
The resolution remained valid even with the exclusion of some members.
2. On jurisdiction: The court held that it did not have jurisdiction to review the validity
of the resolution, as it was a political question.
The judiciary lacks jurisdiction over political questions related to the resolution.
3. On the certification's conclusiveness: The court ruled that the certification by the
presiding officers of Congress was conclusive and binding on the courts.
The certification by Congress's presiding officers is final and binding.
Ratio:
1. Exclusion of Members: The court found that the exclusion of certain members did
not invalidate the resolution.
Legislative process and membership determination are political questions
beyond judicial review.
2. Jurisdiction: The court reiterated the doctrine that political questions are not within
the judiciary's province unless expressly provided by the constitution or statute.
Proposal and ratification of constitutional amendments are political functions
entrusted to Congress.
3. Certification's Conclusiveness: The court upheld the "enrolled bill rule," which
states that a duly authenticated bill or resolution, signed by the presiding officers and
secretaries of the legislative bodies, is conclusive proof of its validity.
The judiciary must respect the legislative branch's certifications, recognizing the
separation of powers doctrine.
The court's decision emphasized the importance of maintaining the separation of powers
and respecting the roles and functions of the legislative and executive branches in the
constitutional amendment process.
The ruling underscored that the judiciary should not intervene in political questions and
should rely on the certifications provided by the legislative officers as conclusive
evidence of the proper enactment of laws and resolutions.
