Case Digest (G.R. No. 63208-09) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On October 27, 1988, the Supreme Court resolved a special civil action for certiorari filed by Firdausi Smail Abbas and twenty-four other petitioners against the Senate Electoral Tribunal. On October 9, 1987, the petitioners initiated SET Case No. 002-87, contesting the proclamation of 22 LABAN coalition candidates as senators-elect following the May 11, 1987 congressional elections. The respondent Tribunal was composed of three Supreme Court justices—Senior Associate Justice Pedro L. Yap (Chairman), Associate Justices Andres R. Narvasa and Hugo E. Gutierrez, Jr.—and six Senators (Joseph E. Estrada, Neptali A. Gonzales, Teofisto T. Guingona, Jose Lina, Jr., Mamintal A.J. Tamano, and Victor S. Ziga). On November 17, 1987, petitioners (excluding Estrada but including Senator Juan Ponce Enrile, who had replaced Estrada) filed a Motion for Disqualification or Inhibition of all six Senator-members on grounds of personal interest. Earlier, Senator Rene A.V. Saguisag had lodged a Petit Case Digest (G.R. No. 63208-09) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Nature of the Action
- Petitioners are twenty-four Senators-elect who filed a Special Civil Action for certiorari to nullify and set aside two Resolutions of the Senate Electoral Tribunal (SET) dated February 12 and May 27, 1988.
- Respondent is the SET, then composed of nine members: Senior Associate Justice Pedro L. Yap (Chairman), Associate Justices Andres R. Narvasa and Hugo E. Gutierrez, Jr., and Senators Joseph E. Estrada, Neptali A. Gonzales, Teofisto T. Guingona, Jose Lina, Jr., Mamintal A.J. Tamano and Victor S. Ziga.
- Underlying Election Contest and Disqualification Motions
- On October 9, 1987, petitioners docketed SET Case No. 002-87, contesting the proclamation of twenty-two LABAN coalition candidates in the May 11, 1987 Senate elections.
- On November 17, 1987, petitioners (excluding Estrada but including Enrile, his designated substitute) filed a Motion for Disqualification/Inhibition of the six Senator-Members of the Tribunal, alleging they were interested parties as respondents in the contest.
- Prior to that, respondent-Senators Rene A.V. Saguisag and Vicente T. Paterno filed petitions and comments to recuse the same Tribunal members on similar grounds. Memoranda were submitted and oral arguments heard before the Resolutions denying all such motions were issued.
- Senator Juan Ponce Enrile voluntarily inhibited himself from participating in both SET Case Nos. 002-87 and 001-87, citing personal involvement.
- Petitioners’ Argument and Proposed Rule Amendment
- Petitioners maintained that due process and fair play required mass disqualification of the Senator-Members and that the doctrine of necessity did not foreclose a constitutional solution.
- They proposed amending SET Rules (new Section 24) to permit adjudication by any three remaining members—provided at least one is a Justice—if more than four members are disqualified, with decisions by majority vote and no abstentions.
Issues:
- Propriety of Disqualification/Inhibition
- Did the SET gravely abuse its discretion in denying the petitioners’ Motion for Disqualification/Inhibition of the six Senator-Members on the ground of partiality and interest?
- Validity of Proposed Rule Amendment
- Is the proposed amendment to the SET Rules—allowing only the three Supreme Court Justices to decide the contest—feasible and constitutional under Article VI, Section 17 of the 1987 Constitution?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)