Alvarez v. Guingona – G.R. No. 118303 – 252 SCRA 695

Facts:

On April 18, 1993, HB No. 8817, entitled “An Act Converting the Municipality of Santiago into an Independent Component City to be known as the City of Santiago,” was filed in the House of Representatives. Meanwhile, a counterpart of HB No. 8817, Senate Bill No. 1243, was filed in the Senate. On March 22, 1994, the House of Representatives, upon being apprised of the action of the Senate, approved the amendments proposed by the Senate.

Issue:

Does the passing of SB No. 1243, the Senate’s own version of HB No. 8817, into Republic Act No. 7720 be said to have originated in the House of Representatives as required?

Held:

Yes. Although a bill of local application should originate exclusively in the House of Representatives, the claim of petitioners that Republic Act No. 7720 did not originate exclusively in the House of Representatives because a bill of the same import, SB No. 1243, was passed in the Senate, is untenable because it cannot be denied that HB No. 8817 was filed in the House of Representatives first before SB No. 1243 was filed in the Senate.

The filing in the Senate of a substitute bill in anticipation of its receipt of the bill from the House, does not contravene the constitutional requirement that a bill of local application should originate in the House of Representatives, for as long as the Senate does not act thereupon until it receives the House bill.

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