Case Digest (G.R. No. 134577)
Facts:
Sen. Miriam Defensor Santiago and Sen. Francisco S. Tatad v. Sen. Teofisto T. Guingona, Jr. and Sen. Marcelo B. Fernan, G.R. No. 134577, November 18, 1998, Supreme Court En Banc, Panganiban, J., writing for the Court.Petitioners Sen. Miriam Defensor Santiago and Sen. Francisco S. Tatad filed an original petition for quo warranto under Rule 66, §5 of the Rules of Court on July 31, 1998, seeking to oust Sen. Teofisto T. Guingona, Jr. as Senate minority leader and to have Sen. Tatad declared the rightful minority leader. The Court required comments (Aug. 4, 1998); respondents and the Solicitor General filed comments on Aug. 25, 1998; petitioners filed a consolidated reply on Sept. 23, 1998; the petition was given due course and deemed submitted for decision on Sept. 29, 1998. No lower court adjudication preceded the original petition.
The factual trigger was the opening of the 11th Congress. On July 27, 1998 the Senate convened to elect officers. By a vote of 20 to 2, Sen. Marcelo B. Fernan was elected Senate President; Sen. Franklin M. Drilon was chosen majority leader. Sen. Tatad asserted, with Sen. Santiago’s alleged agreement, that he and Santiago comprised the minority and that he would assume the minority leadership. Conversely, the seven senators of Lakas-NUCD-UMDP, claiming minority status, held a caucus and voted to elect Sen. Guingona as minority leader; Sen. Fernan, after receiving their letter, formally recognized Guingona on July 30, 1998. Petitioners promptly filed the quo warranto petition alleging usurpation and unlawful exercise of the minority leader position, and, alternatively, that Sen. Fernan gravely abused his discretion in recognizing Guingona.
No constitutional provision, statute, or Senate rule was cited by petitioners to prescribe who constitutes the "minority" or the prec...(Pro-only)
Issues:
- Does the Supreme Court have jurisdiction over the petition challenging the recognition of the Senate minority leader?
- Did the recognition of Sen. Guingona as minority leader violate the Constitution?
- Was Sen. Guingona usurping, unlawfully holding or exercising the position of Senate minority leader?
- Did Sen. Fernan commit grave abuse of discretion in recognizing Sen...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)