ERNESTO B. FRANCISCO, JR.

, petitioner,

NAGMAMALASAKIT NA MGA MANANANGGOL NG MGA MANGGAGAWANG PILIPINO, INC., ITS OFFICERS AND MEMBERS,
petitioner-in-intervention,

G.R. 160261

Facts: In June 2 2003, an impeachment complaint was lodged against Chief Justice Hilario Davide and seven Associate
Justices. However, The House Committee on Justice dismissed it on October 22, 2003, citing insufficient substance.

Subsequently, Representative Gilbert Teodoro and Felix Fuentabella filed a new impeachment complaint against Chief
Justice Davide on October 23, 2003. Petitions were brought against the House of Representatives and others, arguing
that the second impeachment filing contradicted the Constitution's Section 5, Article XI, provision, which limits initiating
impeachment proceedings against the same official more than once within a year.

Senator Pimentel Jr. sought to intervene, asserting that the petitions should be dismissed due to the Senate's sole power
and jurisdiction as the impeachment court, as stated in Article XI of the Constitution.

Issue: Whether or not the Court has jurisdiction, according to Article XI of the Constitution, to determine the validity of
the second impeachment complaint.

Ruling: No, the second impeachment complaint is prohibited under Section 3(5) of Article XI of the Constitution. The
Constitution should be interpreted holistically, and the provision's terms must align with other constitutional clauses.

Doctrine: The case of Ernesto B. Francisco, Jr. & al. vs. The House of Representatives et al. (G.R. 160261) provides a
constitutional doctrine emphasizing strict adherence to the Constitution's constraints on impeachment procedures. It
emphasizes the significance of respecting the ideas stated in the Constitution while safeguarding democratic
government procedures.

The idea contends that, as the supreme law of the land, the Constitution imposes specific constraints and circumstances
on the initiation and conduct of impeachment proceedings against public officials. It emphasizes the significance of the
Constitution's provisions, such as the restriction on beginning impeachment proceedings against the same official more
than once in a year, as stated in Article XI, Section 3(5) of the Constitution. The case of Ernesto B. Francisco, Jr. et al. vs.
The House of Representatives et al. (G.R. 160261) establishes a constitutional doctrine emphasizing strict adherence to
the restrictions on impeachment proceedings imposed by the Constitution. It underlines the importance of upholding
democratic government methods while honoring the values contained in the Constitution.

According to the theory, the Constitution, as the ultimate law of the land, imposes precise limits and circumstances on
the initiation and conduct of impeachment proceedings against public officials. It stresses the importance of the
Constitution's provisions, such as the prohibition on initiating impeachment proceedings against the same official more
than once per year, as specified in Article XI, Section 3(5) of the Constitution.

The case of Ernesto B. Francisco, Jr. et al. vs. The House of Representatives et al. (G.R. No. 160261) involves a petition
challenging the constitutionality of the second impeachment complaint filed against Chief Justice Hilario Davide and
several Associate Justices. The case revolves around the interpretation of the constitutional provision regarding
impeachment proceedings, particularly the prohibition against initiating multiple impeachment proceedings against the
same official within a year.

Key Parties:

Petitioner: Ernesto B. Francisco, Jr.

Petitioner-in-Intervention: Nagmamalasakit na mga Manananggol ng mga Manggagawang Pilipino, Inc., its Officers and
Members; World War II Veterans Legionaries of the Philippines, Inc.

Respondents: 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.; Representative Felix William B. Fuentebella.

Respondent-in-Intervention: Jaime N. Soriano; Senator Aquilino Q. Pimentel.

Facts:

An impeachment complaint was filed against Chief Justice Hilario Davide and several Associate Justices on June 2, 2003.

The House Committee on Justice dismissed the first impeachment complaint on October 22, 2003, deeming it insufficient
in substance.

Following the dismissal, Representative Gilberto C. Teodoro and Representative Felix William B. Fuentebella filed a new
impeachment complaint against Chief Justice Davide on October 23, 2003.

Various petitions were brought before the court, arguing that the filing of the second impeachment complaint was
unconstitutional. They contended that it violated the provision of Section 3(5), Article XI of the Constitution, which states
that "no impeachment proceedings shall be initiated against the same official more than once within the period of one
year."

Senator Aquilino Q. Pimentel also filed a Motion to Intervene, asserting that the Court lacks jurisdiction over the matter
and that the sole authority of the Senate as the impeachment court should be upheld, as stated in Article XI of the
Constitution.

Issue:

The main issue was whether the Court had jurisdiction, according to Article XI of the Constitution, to determine the
validity of the second impeachment complaint.

The case revolves around the interpretation of constitutional provisions related to impeachment, the separation of
powers between branches of government, and the concept of jurisdiction in impeachment proceedings.

Whether or not the Judiciary Can Review Legislative Proceedings:

Yes, in certain cases, the judiciary can review legislative proceedings, particularly in matters like impeachment cases, to
ensure adherence to constitutional provisions.

Whether or not the Constitution's Impeachment Provisions are Self-Contained:

No, the Constitution's impeachment provisions are not self-contained; they are subject to interpretation and may need
to be harmonized with other constitutional principles.

Whether or not Constitutional Provisions on Impeachment are Absolute:

No, constitutional provisions on impeachment are not absolute; their interpretation can be nuanced and context-
dependent.

Whether or not Judicial Interpretation Impacts Impeachment Proceedings:

Yes, judicial interpretation can impact impeachment proceedings by providing clarity on the scope and limitations of
constitutional provisions.

Whether or not Impeachment is Governed Solely by Legislative Prerogative:

No, impeachment is not governed solely by legislative prerogative; it is subject to constitutional limitations that the
judiciary can review.

Whether or not Constitutional Safeguards Can Be Eroded:

No, constitutional safeguards cannot be eroded; they should be preserved to uphold democratic principles and prevent
abuses.

These interconnected answers reflect the complex relationship between constitutional provisions, branches of
government, and the role of the judiciary in ensuring the constitutionality and integrity of processes like impeachment.
Title: CIVIL LIBERTIES UNION vs. THE EXECUTIVE SECRETARY

G.R. Nos.: 83896 & 83815

Date: February 22, 1991

Facts:

On February 22, 1991, the Civil Liberties Union (CLU) filed a petition for prohibition and mandamus with a prayer for a
temporary restraining order and/or preliminary injunction.

The petition seeks to restrain the Executive Secretary from implementing a circular issued by the Department of National
Defense (DND), which was issued on a certain date and directs members of the military to refuse invitations for
interviews, press conferences, and other public forums.

The CLU contends that the circular infringes upon the freedom of speech and of the press, as well as the right of the
people to information on matters of public concern.

The respondents, including the Executive Secretary, argue that the issuance of the circular was within the Department of
National Defense's authority, aimed at promoting good order and discipline in the military.

Issues:

Whether or not the circular issued by the Department of National Defense violates the constitutional rights to freedom
of speech, freedom of the press, and the right to information.

Whether or not the issuance of the circular by the Department of National Defense is within its authority and valid.

Ruling:

Yes, the circular violates the constitutional rights to freedom of speech, freedom of the press, and the right to
information.

The Supreme Court recognized that while the military has special concerns that may justify certain restrictions, these
concerns cannot be used to unduly curtail the exercise of fundamental rights.

The circular's broad prohibition on military personnel from participating in interviews, press conferences, and public
forums is an overbroad restriction that goes beyond the legitimate interest of the military.

The Court held that the freedom of speech and the right to information are vital for a well-informed citizenry and for the
democratic governance of the nation. Restrictions on these rights must be justified by a compelling state interest, and
the circular failed to meet this standard.

No, the issuance of the circular is not within the Department of National Defense's authority and is invalid.

While the Department of National Defense may have authority to issue regulations related to the military's internal
affairs, these regulations must still respect the constitutional rights of military personnel and citizens.

The circular's prohibition was not reasonable or necessary to achieve the goal of good order and discipline. The circular's
lack of precision and its broad scope raised concerns about its potential abuse and the infringement of constitutionally
protected rights.

Doctrine:
The freedom of speech, freedom of the press, and the right to information are vital components of a democratic society.
Any restrictions on these rights must be narrowly tailored to serve a compelling state interest and must not unduly
curtail the exercise of these rights.

Significance:

The case reinforces the principle that even within the context of military affairs, constitutional rights must be respected
and any restrictions imposed must be reasonable, necessary, and narrowly tailored to achieve a legitimate state interest.
This decision upholds the importance of protecting freedom of speech, freedom of the press, and the right to
information as cornerstones of democracy.
Title: MANILA PRINCE HOTEL vs. GOVERNMENT SERVICE INSURANCE SYSTEM

G.R. No.: 122156

Date: February 3, 1997

Facts:

On January 28, 1992, the Government Service Insurance System (GSIS) published an invitation to bid for the sale of
Manila Hotel Corporation (MHC) through public bidding.

Manila Prince Hotel, a competitor in the hotel industry, obtained the bidding documents and participated in the bidding
process.

On March 19, 1992, Manila Prince Hotel submitted a bid, which was higher than the minimum price set by GSIS.
However, on April 20, 1992, the bid was rejected by the GSIS Board of Trustees.

The sale was eventually awarded to Renong Berhad, a Malaysian firm.

On June 3, 1992, Manila Prince Hotel filed a complaint before the Supreme Court to challenge the sale of Manila Hotel to
Renong Berhad.

Issues:

Whether or not the sale of Manila Hotel to Renong Berhad is violative of the Constitution and other laws.

Whether or not the privatization of Manila Hotel constitutes a waiver of the Philippines' national patrimony.

Ruling:

Yes, the sale of Manila Hotel to Renong Berhad is violative of the Constitution and other laws.

The Supreme Court ruled that the sale violated Section 10, Article XII of the 1987 Constitution, which prohibits the
alienation of lands of the public domain, including patrimonial lands, to foreigners or corporations at least 60% of the
capital of which is owned by foreigners. Manila Hotel, being a historic landmark and part of the country's national
patrimony, falls under the classification of patrimonial property.

The Court also emphasized that the right of first refusal of the GSIS on the hotel property under the MOA with Manila
Hotel Corporation was disregarded.

No, the privatization of Manila Hotel does not constitute a waiver of the Philippines' national patrimony.

While the government is allowed to enter into agreements with foreign corporations for the development of the
country's economy, such agreements must be in accordance with the Constitution.

The Court held that the failure to comply with the constitutional requirements in the sale of Manila Hotel cannot be
justified by invoking the need for foreign investments or the potential benefits to the economy.

Doctrine:

The sale of public or patrimonial property, especially those considered as part of the national patrimony, to foreign
entities must be strictly in accordance with the Constitution's requirements and safeguards.

Significance:

The case of Manila Prince Hotel vs. GSIS underscores the importance of upholding constitutional provisions safeguarding
the national patrimony and public interest in transactions involving the sale of important national assets. The decision
established that constitutional provisions cannot be easily bypassed, even in cases where economic considerations are
raised.
Title: CIVIL LIBERTIES UNION vs. THE EXECUTIVE SECRETARY

G.R. No.: 83896

Date: February 22, 1991

Facts:

On February 22, 1991, the Civil Liberties Union (CLU) filed a petition for prohibition and mandamus with a prayer for a
temporary restraining order and/or preliminary injunction.

The petition seeks to restrain the Executive Secretary from implementing a circular issued by the Department of National
Defense (DND), which was issued on a certain date and directs members of the military to refuse invitations for
interviews, press conferences, and other public forums.

The CLU contends that the circular infringes upon the freedom of speech and of the press, as well as the right of the
people to information on matters of public concern.

Issues:

Whether or not the circular issued by the Department of National Defense violates the constitutional rights to freedom
of speech, freedom of the press, and the right to information.

Whether or not the issuance of the circular by the Department of National Defense is within its authority and valid.

Ruling:

Yes, the circular violates the constitutional rights to freedom of speech, freedom of the press, and the right to
information.

The Supreme Court recognized that while the military has special concerns that may justify certain restrictions, these
concerns cannot be used to unduly curtail the exercise of fundamental rights.

The circular's broad prohibition on military personnel from participating in interviews, press conferences, and public
forums is an overbroad restriction that goes beyond the legitimate interest of the military.

The Court held that the freedom of speech and the right to information are vital for a well-informed citizenry and for the
democratic governance of the nation. Restrictions on these rights must be justified by a compelling state interest, and
the circular failed to meet this standard.

No, the issuance of the circular is not within the Department of National Defense's authority and is invalid.

While the Department of National Defense may have authority to issue regulations related to the military's internal
affairs, these regulations must still respect the constitutional rights of military personnel and citizens.

The circular's prohibition was not reasonable or necessary to achieve the goal of good order and discipline. The circular's
lack of precision and its broad scope raised concerns about its potential abuse and the infringement of constitutionally
protected rights.

Doctrine:

The freedom of speech, freedom of the press, and the right to information are vital components of a democratic society.
Any restrictions on these rights must be narrowly tailored to serve a compelling state interest and must not unduly
curtail the exercise of these rights.
Significance:

The case reinforces the principle that even within the context of military affairs, constitutional rights must be respected
and any restrictions imposed must be reasonable, necessary, and narrowly tailored to achieve a legitimate state interest.
This decision upholds the importance of protecting freedom of speech, freedom of the press, and the right to
information as cornerstones of democracy.
Title: Raul L. Lambino and Erico B. Aumentado, together with 6,327,952 registered voters, Petitioners vs. The
Commission on Elections, Respondent

G.R. No.: 174153

Date: October 25, 2006

Facts:

On October 25, 2006, Raul L. Lambino and Erico B. Aumentado, along with 6,327,952 registered voters, filed a petition
against the Commission on Elections (COMELEC).

The petition challenges the validity of a COMELEC resolution that denied the initiative petition to amend the
Constitution, particularly the creation of a new legislative district in Southern Leyte.

The petitioners claim that the COMELEC's decision is unconstitutional and violates the people's right to initiative. They
assert that the COMELEC's act is tantamount to grave abuse of discretion.

Issues:

Whether or not the COMELEC resolution denying the initiative petition is unconstitutional.

Whether or not the COMELEC committed grave abuse of discretion in denying the initiative petition.

Ruling:

No, the COMELEC resolution denying the initiative petition is not unconstitutional.

The Supreme Court ruled that the COMELEC's act of denying the initiative petition was not unconstitutional. The Court
emphasized that the initiative process should adhere to the Constitution's strict requirements, and the COMELEC has the
authority to scrutinize and verify the sufficiency of the petition.

No, the COMELEC did not commit grave abuse of discretion in denying the initiative petition.

The Court held that the COMELEC's decision was based on legal and constitutional grounds. It was not arbitrary or
capricious, and there was no showing of grave abuse of discretion in the denial of the initiative petition.

Doctrine:

The COMELEC has the authority to review and verify the sufficiency of initiative petitions, and its denial of such petitions
should be based on valid legal and constitutional grounds.

Significance:

This case reinforces the principle that the process of initiative to amend the Constitution must strictly adhere to
constitutional requirements. It also underscores the authority of the COMELEC to review and evaluate the validity of
initiative petitions, ensuring that the people's power of initiative is exercised within legal boundaries.
Title: Ramon A. Gonzales, Petitioner vs. Commission on Elections, Director of Printing, and Auditor General (G.R. No. L-
28196)

Title: Philippine Constitution Association (PHILCONSA), Petitioner vs. Commission on Elections (G.R. No. L-28224)

G.R. No.: L-28196 and L-28224

Date: November 9, 1967

Facts:

On November 9, 1967, two cases were consolidated: G.R. No. L-28196 filed by Ramon A. Gonzales and G.R. No. L-28224
filed by the Philippine Constitution Association (PHILCONSA).

Both cases seek to challenge the constitutionality of Republic Act No. 4913, which proposes amendments to certain
articles of the Constitution.

Ramon A. Gonzales, in G.R. No. L-28196, argues that Republic Act No. 4913, as it was submitted to the people for
ratification, is unconstitutional because it fails to comply with the manner prescribed by the Constitution for proposing
amendments.

PHILCONSA, in G.R. No. L-28224, raises similar arguments, asserting that Republic Act No. 4913 is void due to non-
compliance with constitutional requirements.

Issues:

Whether or not Republic Act No. 4913, proposing amendments to the Constitution, is unconstitutional due to non-
compliance with the manner prescribed by the Constitution.

Whether or not the petitions questioning the constitutionality of Republic Act No. 4913 have legal standing.

Ruling:

Yes, Republic Act No. 4913 is unconstitutional due to non-compliance with the manner prescribed by the Constitution.

The Supreme Court ruled that Republic Act No. 4913 is unconstitutional. The Act proposed amendments to the
Constitution through a joint resolution, which does not adhere to the proper procedure for amending the Constitution.
The Court emphasized that the Constitution itself provides the method for proposing amendments, and this process
must be strictly followed.

Yes, the petitions questioning the constitutionality of Republic Act No. 4913 have legal standing.

The Court recognized the legal standing of the petitioners, both Gonzales and PHILCONSA, to question the
constitutionality of Republic Act No. 4913. As citizens and taxpayers, they possess sufficient interest in ensuring that the
Constitution is not violated and that the proper process for amending it is observed.

Doctrine:

The process for amending the Constitution, as prescribed by the Constitution itself, must be strictly followed. Failure to
comply with the constitutionally mandated procedure renders the proposed amendments unconstitutional.

Significance:

These cases reinforce the importance of adhering to the constitutional process for proposing amendments to the
Constitution. The Court's decision highlights the principle that the Constitution is the supreme law of the land, and any
attempt to amend it must be carried out in accordance with the procedures outlined in the Constitution itself.