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Francisco v House of Representatives The Court issued a resolution to:

On July 22, 2002, the House of Representatives adopted a a. Consolidate all the petitions
Resolution,2 sponsored by Representative Felix William D. b. Require respondent House of Representatives and
Fuentebella, which directed the Committee on Justice "to Senate, as well as the Solicitor General, to comment
conduct an investigation, in aid of legislation, on the manner on the petitions
of disbursements and expenditures by the Chief Justice of the c. Set the date for the oral arguments
Supreme Court of the Judiciary Development Fund (JDF)." 3 d. Appoint distinguished legal experts are amici curiae

On June 2, 2003, former President Joseph E. Estrada filed an


impeachment complaint4 (first impeachment complaint)
against Chief Justice Hilario G. Davide Jr. and seven Associate Speaker Jose C. De Venecia Jr submitted a Manifestation
Justices5 of this Court for "culpable violation of the asserting that the Court has no jurisdiction to hear, much less
Constitution, betrayal of the public trust and other high prohibit or enjoin, the House of the Representatives which is
crimes."6 The complaint was endorsed by Representatives an independent and co-equal branch of the government.
Rolex T. Suplico, Ronaldo B. Zamora and Didagen Piang
Dilangalen,7 and was referred to the House Committee on Senator Aquilino Pimentel filed a Motion to Intervene praying
Justice on August 5, 20038 in accordance with Section 3(2) of that “the consolidated petitions be dismissed for lack of
Article XI of the Constitution. jurisdiction of the Court over the issues affecting the
impeachment proceedings and that the sole power of the
The House Committee on Justice dismissed the impeachment Senate as the impeachment court be upheld pursuant to the
complaint because while it was sufficient in form, it was not provisions of Article XI of the Constitution.
sufficient in substance based on the Impeachment guidelines
promulgated by the 12th Congress. Senate President Franklin Drilon filed a Manifestation stating
that the petitions are pre-mature because the duty of the
Four months and three weeks since the filing on June 2, 2003 Sentate to commence the impeachment court starts only
of the first complaint or on October 23, 2003, a day after the upon receipt of the Articles of Impeachment which the
House Committee on Justice voted to dismiss it, the second Senate did not.
impeachment complaint11 was filed with the Secretary
General of the House12 by Representatives Gilberto C. Issue:
Teodoro, Jr. (First District, Tarlac) and Felix William B. 1. WON the power of judicial review extends to those
Fuentebella (Third District, Camarines Sur) against Chief arising from impeachment proceedings
Justice Hilario G. Davide, Jr., founded on the alleged results of 2. WON The essential pre-requisites for the exercise of
the legislative inquiry initiated by above-mentioned House judicial review fulfilled
Resolution. This second impeachment complaint was 3.
accompanied by a "Resolution of Congress and Court are in Constitutional deadlock.
Endorsement/Impeachment" signed by at least one-third
(1/3) of all the Members of the House of Representatives.13 Court Reasoning

Petitions bearing docket numbers G.R. Nos. 160261, 160262 Judicial Review
and 160263, the first three of the eighteen which were filed
before this Court,18 prayed for the issuance of a Temporary 1. Duty of the court to settle actual controversies which
Restraining Order and/or preliminary injunction to prevent involves rights that are legally demandable and
the House of Representatives from transmitting the Articles enforceable, and determine where or not there is
of Impeachment arising from the second impeachment grave abuse of discretion amounting to lack or
complaint to the Senate. Petition bearing docket number G.R. excess in jurisdiction of the branch or instrumentality
No. 160261 likewise prayed for the declaration of the of the government.
November 28, 2001 House Impeachment Rules as null and a. Expanded certiorari jurisdiction of the cour
void for being unconstitutional. b. Not only a power but a duty because
expressly provided in Constitution
Petitions bearing docket numbers G.R. Nos. 160277, 160292 2. Angara vs Electoral Commission – in cases of conflict,
and 160295, which were filed on October 28, 2003, sought the judicial department is the only governmental
similar relief. In addition, petition bearing docket number G.R. organ that can be called upon to settle disputes on
No. 160292 alleged that House Resolution No. 260 (calling for the proper allocation of powers between
a legislative inquiry into the administration by the Chief departments of the government
Justice of the JDF) infringes on the constitutional doctrine of 3. Limitations and restrictions are set so as not to make
separation of powers and is a direct violation of the the sepatation of powers mere words, bill of rights
constitutional principle of fiscal autonomy of the judiciary.
mere expressions of sentiment, and good override it which is all done in the impeachment
governance as suggestive proceedings consisting of a beginning (filing), middle
4. When the judiciary mediates in the allocation of (deliberation), and end (decision).
constitutional boundaries, it does not assert its
dominance over the other branches of government. The impeachment case is the successful
It is simply doing what the Constitution mandated it
charging of a public official with impeachment
to do.
5. Regarding the merits of the issued raised by the and now subject to trial by the Senate.
petition, the court turn to the Consti and its words
should be VALIDITY OF THE SECOND IMPEACHMENT CASE
a. Given ordinary meaning
b. Interpret according to the intent of framers Having concluded that the initiation takes place
c. Interpret as a whole – no provision is alone
6. De Venecia: Impeachment is a political action which by the act of filing of the impeachment
cannot assume a judicial character complaint and its referral to the Committee on
Pimentel: power of senate to try impeachment cases Justice, the meaning of Section 3 (5) Article XI
excludes judicial review becomes clear. No impeachment complaint
7. Court is the final arbiter on the question whether or may be filed against the same public official
not a branch of government has acted without or in
excess of jurisdiction. Constitution should be within a period of 1 year. Therefore this renders
interpreted as a whole because no one provision the 2nd impeachment complaint as a violation
should defeat the other. to the Constitution.

Essential Requisites for Judical Review


Held:
1. Locus standi or legal standing
2. Ripeness and Prematurity The framers intended "initiation" to start with the filing of the
3. Lis Mota or the crux of the controversy complaint. The framers also understood “initiation” in its
a. WON Sec 15 and 16 of Rule 5 of the House ordinary meaning wherein the “initiation” refers to the filing
Impeachment Rules violate Sec 3 Article XI of the complaint and not upon after Congress vote of least
(initiate) 1/3.
b. WON second impeachment complaint is
barred under Sec 3(5) Article XI The argument that only the House of Representatives as a
4. Judicial Restraint body can initiate impeachment proceedings because Section
3 (1) says "The House of Representatives shall have the
Constitutionality of the Rules of Procedure exclusive power to initiate all cases of impeachment," is a
misreading of said provision and is contrary to the principle
For De Venecia: The term ‘initiate’ does not mean to file. of reddendo singula singulis by equating "impeachment
It means, for him, that initiation of impeachment cases" with "impeachment proceeding."
proceedings starts when House of Representatives act on
it as a collective body. Before it reaches such, it needs to Court Held:
undergo other processes indicated in the Rules V
WHEREFORE, Sections 16 and 17 of Rule V of the
For the Court: Impeachment proceeding is not a single Rules of Procedure in Impeachment Proceedings
act. It is a complexus of acts that has a beginning, a which were approved by the House of
middle, and an end. End if the transmittal of the Articles Representatives on November 28, 2001 are
of Impeachment to Senate, middle is the deliberation unconstitutional. Consequently, the second
and discussion leading to the end, and the beginning is impeachment complaint against Chief Justice Hilario
the filing of the complaint and referral to the Committee G. Davide, Jr. which was filed by Representatives
on Justice. Gilberto C. Teodoro, Jr. and Felix William B.
Fuentebella with the Office of the Secretary General
Cited the intent of the framers from records and of the House of Representatives on October 23, 2003
court definition is consistent with the intent. is barred under paragraph 5, section 3 of Article XI of
the Constitution.
Impeachment proceeding comes before an impeachment
case. There is only an impeachment case when the House
votes 1/3 to affirm the resolution from The Committee or