Final legislative action; journal entry rule
The journal of the proceedings of each House of Congress is no ordinary
record. (Astorga v. Villegas, G.R. No. L-23475, April 30, 1974)
A bill may become a law, even without the President’s signature, if the
President does not sign a bill within 30 days from receipt in his office. A
bill may also become a law without the President’s signature if Congress
overrides a presidential veto by two-thirds vote.
Under the enrolled bill rule, once an election for the adoption of a statute
is held, the procedural method by which the measure was placed on the ballot
cannot be challenged with a lawsuit since judicial inquiry into legislative
procedure is barred as an intrusion into the internal affairs of the lawmaking
body. https://legal-dictionary.thefreedictionary.com/Enrolled+Bill
The enrolled bill rule is a principle of judicial interpretation of rules of
procedure in legislative bodies. Under the doctrine, once a bill passes a
legislative body and is signed into law, the courts assume that all rules of
procedure in the enactment process were properly followed.
https://en.wikipedia.org/wiki/Enrolled_bill_rule
In the United States, the rule was adopted by the Supreme Court in Field v.
Clark, 143 U.S. 649 (1892). In effect, the court ruled that the enrolled bill
signed by the presiding officers of the two houses of Congress was the best
evidence of what had been passed, being on balance better evidence than the
journals of the respective houses, so it should not be called into question.
https://en.wikipedia.org/wiki/Enrolled_bill_rule
The signing by the Speaker of the House of Representatives, and, by the
President of the Senate, in open session, of an enrolled bill, is an official
attestation by the two houses of such bill as one that has passed Congress. It
is a declaration by the two houses, through their presiding officers, to the
President, that a bill, thus attested, has received, in due form, the sanction
of the legislative branch of the government, and that it is delivered to him
in obedience to the constitutional requirement that all bills which pass
Congress shall be presented to him. And when a bill, thus attested, receives
his approval, and is deposited in the public archives, its authentication as a
bill that has passed Congress should be deemed complete and unimpeachable. As
the President has no authority to approve a bill not passed by Congress, an
enrolled Act in the custody of the Secretary of State, and having the official
attestations of the Speaker of the House of Representatives, of the President
of the Senate, and of the President of the United States, carries, on its
face, a solemn assurance by the legislative and executive departments of the
government, charged, respectively, with the duty of enacting and executing the
laws, that it was passed by Congress. The respect due to coequal and
independent departments requires the judicial department to act upon that
assurance, and to accept, as having passed Congress, all bills authenticated
in the manner stated; leaving the courts to determine, when the question
properly arises, whether the Act, so authenticated, is in conformity with the
Constitution. (G.R. No. L-23475, April 30, 1974)
It may be noted that the enrolled bill theory is based mainly on "the respect
due to coequal and independent departments," which requires the judicial
department "to accept, as having passed Congress, all bills authenticated in
the manner stated." Thus it has also been stated in other cases that if the
attestation is absent and the same is not required for the validity of a
statute, the courts may resort to the journals and other records of Congress
for proof of its due enactment. This was the logical conclusion reached in a
number of decisions, although they are silent as to whether the journals may
still be resorted to if the attestation of the presiding officers is present.
(G.R. No. L-23475, April 30, 1974)
