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The Integrated Bar of the Philippines and several law school deans stated that a June 3, 2026 Senate session reached a valid quorum with 12 senators present. They cited a 1949 Supreme Court ruling to support the position that two absent senators fall outside the chamber's coercive jurisdiction.
RapplerThe Integrated Bar of the Philippines and deans from multiple law schools stated that the Senate session held on June 3, 2026, with 12 senators present, met the constitutional requirement for a quorum. The IBP said the 1949 Supreme Court decision in Avelino v.
Cuenco established that the phrase "majority of each House" refers to available members rather than the full membership. With two senators outside the Senate's power to compel attendance, the total number of available senators was 22, making 12 a majority.
The IBP statement noted that the two absent senators cannot be included in the quorum calculation because the Senate lacks coercive jurisdiction over them. It added that all acts, resolutions, and decisions from the June 3 session are presumed official under the presumption of regularity.
Law deans and professors, including a retired Supreme Court associate justice, issued a joint statement agreeing that only 22 senators were subject to compulsory attendance. They said counting the two absent members would give individuals beyond legal reach the ability to block legislative functions.
The experts pointed out that a similar quorum of 12 occurred on May 5, 2015, and argued the constitutional language contemplates members who are actually present and deliberating.
The statements emphasized that the Senate's composition remains 24 members, the same number that existed when the 1949 ruling was issued. They said the doctrine therefore continues to apply. The June 3 session followed a period in which the chamber had been unable to reach a quorum.
Once the required number was present, senators declared all positions vacant and elected a new Senate president pro tempore along with committee chairs.
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