Case Digest (G.R. No. 22041) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jose Alejandrino vs. Manuel L. Quezon et al., G.R. No. 22041, decided September 11, 1924 under the Philippine Organic Act of 1902 and the Jones Law of 1916, petitioner Jose Alejandrino—appointed Senator by the Governor-General to represent the Twelfth Senatorial District—filed an original action for mandamus and injunction against Senate President Manuel L. Quezon, all sitting Senators, and key Senate officers. On February 5, 1924, the Senate adopted a resolution finding Alejandrino guilty of “disorderly conduct” for assaulting Senator Vicente de Vera during a debate on his credentials and, by a majority vote, “deprived” him of all prerogatives, privileges, and emoluments as Senator for one year from January 1, 1924. The resolution instructed the Secretary, Sergeant-at-Arms, and Paymaster of the Senate to enforce the suspension and notified the Governor-General. Alejandrino sought (1) a preliminary injunction to stop enforcement, (2) a declaration this resolution was null and Case Digest (G.R. No. 22041) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Petitioner: Jose Alejandrino, appointed Senator by the Governor-General to represent the Twelfth Senatorial District.
- Respondents: Manuel L. Quezon (President of the Philippine Senate), members of the Philippine Senate (Isabelo de los Reyes, Santiago Fonacier, Alejo Mabanag, Bernabe de Guzman, Ramon Fernandez, Emiliano T. Tirona, Antero Soriano, Juan B. Alegre, Vicente de Vera, Jose Ma. Arroyo, Francisco Enage, Tomas Gomez, Sergio Osmeña, Celestino Rodriguez, Francisco Soriano, Jose A. Clarin, Hadji Butu, Espiridion Guanco, Hermenegildo Villanueva, Jose Hontiveros, Teodoro Sandiko, Santiago Lucero), and Senate officers (Secretary Faustino Aguilar, Sergeant-at-Arms Bernabe Bustamante, Paymaster Francisco Dayaw).
- Senate Resolution
- Date & substance: February 5, 1924, resolution finding Senator Alejandrino “guilty of disorderly conduct and flagrant violation of the privileges of the Senate” for an alleged assault on Senator Vicente de Vera.
- Penalty imposed: Deprivation of “all his prerogatives, privileges and emoluments” as Senator for one year from January 1, 1924.
- Notice: Copy of resolution furnished to the Governor-General.
- Proceedings in the Supreme Court
- Petition: Alejandrino seeks (a) preliminary injunction barring execution of the resolution, (b) declaration of the resolution’s nullity, and (c) final writ of mandamus and injunction compelling recognition of his senatorial rights and emoluments.
- Defense: Government’s Attorney-General appears specially and demurs, contesting the Court’s jurisdiction over a coordinate branch (the Senate) and its officers.
Issues:
- Jurisdiction
- May the Supreme Court issue mandamus or injunction against the Philippine Senate or its officers to compel or restrain the performance of legislative acts?
- Constitutionality of the Resolution
- Does the Senate possess power under the Organic Act (Jones Law) to suspend or remove an appointive Senator?
- Available Remedy
- If the resolution is void, can the Court compel reinstatement of the Senator and payment of his emoluments through mandamus or injunction?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)