Title
Defensor-Santiago vs. Guingona, Jr.
Case
G.R. No. 134577
Decision Date
Nov 18, 1998
Dispute over Senate Minority Leader position in the Philippines; Supreme Court upheld Senate's internal authority, dismissing quo warranto petition.

Case Digest (G.R. No. 134577)
Expanded Legal Reasoning Model

Facts:

  • Petition and Pleadings
    • On July 31, 1998, Senators Miriam Defensor Santiago and Francisco S. Tatad filed an original petition for quo warranto (Rule 66, §5) seeking the ouster of Senator Teofisto T. Guingona Jr. as Senate minority leader and the declaration of Senator Tatad as the rightful minority leader.
    • August 4, 1998: Court required respondents and the Solicitor General to file Comments within 15 days. Both Comments were filed on August 25, 1998. A Resolution of September 1, 1998 ordered petitioners to file a Consolidated Reply, which was submitted on September 23, 1998. On September 29, 1998, the Court deemed the controversy submitted for decision.
  • Senate Composition and Leadership Dispute
    • The Senate convened on July 27, 1998 for the first regular session of the 11th Congress. Of 24 seats, one was vacant (Vice President). Party affiliation of the 23 sitting senators:
1) Laban ng Masang Pilipino (LAMP): 10 2) Lakas-NUCD-UMDP: 7 3) Liberal Party (LP): 1 4) Aksyon Demokrasya: 1 5) People’s Reform Party (PRP): 1 6) Gabay Bayan: 1 7) Independents: 2
  • Election of Officers (July 27, 1998):
1) Senate President: Marcelo B. Fernan elected by a 20–2 vote over Francisco S. Tatad. 2) President Pro Tempore: Blas F. Ople. 3) Majority Leader: Franklin M. Drilon. 4) Minority Leader Claimants: Tatad, with Santiago’s support, claimed the post as the losing nominee and only other dissenting voter; Lakas-NUCD-UMDP (7 members) caucused and elected Teofisto T. Guingona Jr. as minority leader. 5) July 30, 1998: Senate President Fernan formally recognized Guingona as minority leader.

Issues:

  • Does the Supreme Court have jurisdiction to entertain the petition?
  • Was there a violation of the Constitution, laws or Senate Rules in recognizing Guingona as minority leader?
  • Was Senator Guingona usurping or unlawfully holding the office of minority leader?
  • Did Senate President Fernan commit grave abuse of discretion in recognizing Guingona?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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