Francisco Vs House of Representatives

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ERNESTO B. FRANCISCO, JR.

, petitioner,
NAGMAMALASAKIT NA MGA MANANANGGOL NG MGA MANGGAGAWANG PILIPINO, INC., ITS OFFICERS AND
MEMBERS, petitioner-in-intervention,
WORLD WAR II VETERANS LEGIONARIES OF THE PHILIPPINES, INC., petitioner-in-intervention,
vs.
THE HOUSE OF REPRESENTATIVES, REPRESENTED BY SPEAKER JOSE G. DE VENECIA, THE SENATE, REPRESENTED BY
SENATE PRESIDENT FRANKLIN M. DRILON, REPRESENTATIVE GILBERTO C. TEODORO, JR. AND REPRESENTATIVE
FELIX WILLIAM B. FUENTEBELLA, respondents.
JAIME N. SORIANO, respondent-in-Intervention,
SENATOR AQUILINO Q. PIMENTEL, respondent-in-intervention.

GR NO. 160261
Nov. 10, 2003

Facts:

On July 22, 2002, the House of Representatives decided to investigate how the Chief Justice of the Supreme Court,
Hilario G. Davide, Jr., was using the Judiciary Development Fund.

On June 2, 2003, former President Joseph E. Estrada filed a complaint against the chief justice and seven associates
for “culpable violation of the constitution, betrayal of the public trust, and other high crimes.” (in reference to
Section 2 of Article XI of the Constitution which states, “The President, the Vice-President, the Members of the
Supreme Court, the Members of the Constitutional Commissions, and the Ombudsman may be removed from office
on impeachment for, and conviction of, culpable violation of the Constitution, treason, bribery, graft and corruption,
other high crimes, or betrayal of public trust.”

On October 13, 2003, they determined that the complaint was "sufficient in form." This means that the complaint
was properly filed and structured according to the rules. However, on October 22, 2003, they voted to dismiss the
complaint because it was deemed "insufficient in substance." This suggests that, while the complaint may have
met the formal criteria, it lacked evidence to support the allegations of constitutional violations, betrayal of public
trust, and high crimes mentioned in the complaint. Therefore, the House Committee on Justice concluded that it did
not have a strong enough basis for further consideration.

Just a day after the House Committee on Justice voted to dismiss the first impeachment complaint, a second
impeachment complaint was filed with the Secretary General of the House. This second complaint was filed by
Representatives Gilberto C. Teodoro, Jr. (First District, Tarlac) and Felix William B. Fuentebella (Third District,
Camarines Sur).

The basis for this second complaint was the alleged results of a legislative inquiry (findings, outcomes, conclusions
of an investigation) initiated by a House Resolution. Additionally, the second impeachment complaint was
accompanied by a "Resolution of Endorsement/Impeachment" (agreement/ kasunduan) signed by at least one-
third (1/3) of all the Members of the House of Representatives, indicating significant support for the complaint
among the legislators.

Legal petitions were filed against the House of Representatives and others. Most of these petitions argue that the
filing of the second impeachment complaint is unconstitutional because it violates a provision in Section 5 of
Article XI of the Constitution which states, "no impeachment proceedings shall be initiated against the same official
more than once within a period of one year." In other words, the contention is that initiating a second impeachment
against the same official within a one-year period is unconstitutional.
To assess the validity of the issues raised in the current petitions, the court must refer to the Constitution itself and
its principles, namely:

verba legis - as much as possible, the words used in the Constitution should be given their ordinary and common
meaning, except in cases where technical terms are employed. For it must be accessible to the general public.

ratio legis est anima - if the language of the Constitution is unclear or open to multiple interpretations, the court
should seek to understand the underlying purpose or reason for that provision.

ut ret magis valeat quam pereat - interpret the Constitution in a way that gives it practical and meaningful effect
rather than rendering it meaningless or ineffective.

Issues:

whether or not the power of judicial review extends to those arising from impeachment proceedings; (2) whether
or not the essential pre-requisites for the exercise of the power of judicial review have been fulfilled; and (3) the
substantive... issues yet remaining. These matters shall now be discussed in seriatim.

Issue no. 1

Whether the offenses alleged in the Second impeachment complaint constitute valid impeachable offenses under
the Constitution.

Issue no. 2

Whether the second impeachment complaint was filed in accordance with Section 3(4), Article XI of the Constitution.

Section 3(4), Article XI of the Constitution states, “In case the verified complaint or resolution of impeachment is
filed by at least one-third of all the Members of the House, the same shall constitute the Articles of Impeachment,
and trial by the Senate shall forthwith proceed.”

Issue no. 3

Whether the legislative inquiry by the House Committee on Justice into the Judicial Development Fund is an
unconstitutional infringement of the constitutionally mandated fiscal autonomy (public finances or financial
matters) of the judiciary.

Issue no. 4

Whether Sections 15 and 16 of Rule V of the Rules on Impeachment adopted by the 12th Congress are
unconstitutional for violating the provisions of Section 3, Article XI of the Constitution.

Issue no. 5

Whether the second impeachment complaint is barred under Section 3(5) of Article XI of the Constitution.

Ruling:

The first issue pertains to the merits of the second impeachment complaint, but the court states that it lacks
jurisdiction over this matter. Furthermore, determining what constitutes an impeachable offense is considered a
purely political question, and the Constitution entrusts such determinations to the discretion of the legislative
branch.
Section 2 of Article XI of the Constitution lists six grounds for impeachment, including "other high crimes" and
"betrayal of public trust." However, these terms are not precisely defined in the Constitution, and the framers of the
Constitution did not provide clear-cut definitions or standards for them. This lack of clarity leads to the conclusion
that the issue is a non-justiciable political question that falls beyond the court's judicial power.

The court also clarifies that initiation of impeachment proceedings occurs through the filing of an impeachment
complaint and its referral to the House Committee on Justice. Once initiated in this manner, no other impeachment
complaint may be filed against the same official within a one-year period, in accordance with Article XI, Section 3(5)
of the Constitution.

Interpreting the Constitution as a whole is vital, and no single section should be allowed to negate or undermine
another. Both the separation of powers and the checks and balances mechanisms are essential components of the
constitutional framework, ensuring that no branch of government exceeds its authority.

“WHEREFORE, Sections 16 and 17 of Rule V of the Rules of Procedure in Impeachment Proceedings which were
approved by the House of Representatives on November 28, 2001 are unconstitutional. Consequently, the second
impeachment complaint against Chief Justice Hilario G. Davide, Jr. which was filed by Representatives Gilberto C.
Teodoro, Jr. and Felix William B. Fuentebella with the Office of the Secretary General of the House of Representatives
on October 23, 2003 is barred under paragraph 5, section 3 of Article XI of the Constitution.” - GR NO. 160261

Rule V of the Rules of Procedure in Impeachment Proceedings:

Section 14. Scope of Bar. - No impeachment proceedings shall be initiated against the same official more than once
within a period of one (1) year.

Paragraph 5, Section 3 of Article XI of the Constitution:

No impeachment proceedings shall be initiated against the same official more than once within a period of one year.

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