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G.R. No. L-29658 – 26 SCRA 150 – Political Law – The Legislative Department – Powers of Congress – Lawmaking Power – Legislative Process – Journal vs Enrolled Bill 

Enrique Morales has served as captain in the police department of a city for at least three years but does not possess a bachelor’s degree.

Morales was the chief of the detective bureau of the Manila Police Department and holds the rank of lieutenant colonel.

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He began his career in 1934 as patrolman and gradually rose to his present position. Upon the resignation of the former Chief, Morales was designated acting chief of police of Manila and, at the same time, given a provisional appointment to the same position by the mayor of Manila.

Abelardo Subido, Commissioner of Civil Service, approved the designation of Morales as acting chief but rejected his appointment for “failure to meet the minimum educational and civil service eligibility requirements for the said po