271059/271347/E-02472/E-04036 Representative Edcel C. Lagman, substituted by Albay First District Representative Krisel B. Lagman, et al. Vs. The Congress of the Philippines, et al./Aquilino “Koko” Pimentel III and Pantaleo “Bebot” Alvarez Vs. Lucas P. Bersamin, in his capacity as executive secretary, and Amenah F. Pangandaman, in her capacity as secretary of the Department of Budget and Management/Filipinos for Peace, Justice and Progress Movement, Inc. (FPJPM), represented by its president and chairperson, Joseph F. Cadsawan, and Gloria T. Puzon, chapter Officer Vs. The House of Representatives, et al./Edgar R. Erice and Leila De Lima Vs. The Senate of the Philippines, et al. — Official PDF

Decision 28 G.R. Nos. 271059, 271347, E-02472 and E-04036 The general rule in enacting a law requires that the readings of the bill be made on three separate days and that the bill in its final form be distributed three days before its passage. However, this procedure is not mandatory in cases where the president certifies a bill as urgent to meet a public calamity or emergency .150 Tolentino v. Secretary of Finance 151 elaborated on the dual purpose behind the requirement of three readings on separate days: "(1) to inform the members of Congress of what they must vote on and (2) to give them notice that a measure is progressing through the enacting process, thus enabling them and others interested in the measure to prepare their positions with reference to it." 152 The exception to such requirement, however, is based on the prudential consideration that if all bills are passed following the three-reading rule across separate days, "the need for a law may be rendered academic by the occurrence of the very emergency or public calamity which is meant to address." 153 Calleja v. Executive Secretary154 explained that "the President's determination of the existence of an 'emergency' or 'public calamity' is fundamentally dependent on the exigencies of each circumstance:"155 The Court held: In Tolentino v. Secretary ofFinance (Tolentino), the Court held that: The sufficiency of the factual basis of the suspension of the writ of habeas corpus or declaration of martial law Art. VII, Section 18, or the existence of a national emergency justifying the delegation of extraordinary powers to the President under Art. VI, Section 23(2) is subject to judicial review because basic rights of individuals may be of hazard. But the factual basis of presidential certification of bills, which involves doing away with procedural requirements designed to insure that bills are duly considered by members of Congress, certainly should elicit a different standard of review. Based on the foregoing, it can be surmised that the President's determination of the existence of an "emergency" or "public calamity" is fundamentally dependent on the exigencies of each circumstance. In Ahas Kida v. Senate of the Philippines, the Court upheld the certification of the President for the immediate enactment of R.A. No. IO 153, a law synchronizing the ARMM elections with the national and local ISO CONST., mt VI, sec. 26(2). "' 319 Phil. 755 (1995) [Per J. Mendoza, En Banc]. 152 Id. ·at 78 ! . 153 Id. at 780-781. 154 918-B Phil. I (2021) [Per J. Carandang, En Banc]. 155 Id. at 269.