Case Digest (A.M. No. MTJ-93-877) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On June 2, 2003, former President Joseph E. Estrada filed a verified impeachment complaint in the House of Representatives against Chief Justice Hilario G. Davide, Jr. and seven Associate Justices of the Supreme Court, charging them with “culpable violation of the Constitution, treason, bribery, graft and corruption, other high crimes, or betrayal of public trust.” The complaint was referred to the House Committee on Justice, which on October 13, 2003 ruled it sufficient in form but, on October 22, 2003, voted to dismiss it as insufficient in substance. On October 23, 2003, Representatives Gilberto C. Teodoro, Jr. and Felix William B. Fuentebella filed a second impeachment complaint against Chief Justice Davide alone, alleging misuse of the Judiciary Development Fund (JDF). It was accompanied by a “Resolution of Endorsement” signed by at least one-third of all House members. As the sponsors prepared to move for transmittal of the complaint to the Senate, various citizens, lawyer Case Digest (A.M. No. MTJ-93-877) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- First Impeachment Complaint
- On June 2, 2003, former President Joseph Estrada filed a verified impeachment complaint with the House of Representatives accusing Chief Justice Hilario G. Davide, Jr. and seven Associate Justices of “culpable violation of the Constitution, treason, bribery, graft and corruption, other high crimes, or betrayal of public trust.”
- The complaint was referred to the House Committee on Justice, which included it in its Order of Business on October 13, 2003 and deemed it sufficient in form; on October 22, 2003, the Committee dismissed it for insufficiency in substance.
- Second Impeachment Complaint and Court Proceedings
- On October 23, 2003, Representatives Gilberto C. Teodoro, Jr. and Felix W. B. Fuentebella filed a second verified impeachment complaint against Chief Justice Davide alone, charging irregularities in the Judiciary Development Fund (JDF).
- At least one-third of all House members signed a “Resolution of Endorsement/Impeachment” for the October 23 complaint. The House adjourned for lack of quorum before transmitting the articles of impeachment to the Senate.
- Between October 27 and 28, 2003, multiple taxpayers, citizens, lawyers, Members of the House, and organizations filed petitions for certiorari, prohibition, mandamus, injunction and annulment of Sections 16 and 17, Rule V of the House Rules on Impeachment Proceedings and of the second impeachment complaint.
- On October 28, 2003, the Supreme Court en banc issued a status quo injunction, consolidated the petitions, appointed amici curiae, and set oral arguments for November 5–6, 2003. The House Speaker and Senate President filed Manifestations challenging the Court’s jurisdiction; Senator Pimentel intervened.
Issues:
- Jurisdiction and justiciability
- Does the Supreme Court have authority under the 1987 Constitution (Art. VIII, Secs. 1 and 4) to review alleged grave abuse of discretion by the House in impeachment proceedings?
- Are the petitions ripe for decision, or do they present nonjusticiable political questions?
- Constitutionality of House Impeachment Rules
- Do Sections 16 and 17, Rule V of the House Rules on Impeachment Proceedings violate Article XI, Sec. 3(5) of the 1987 Constitution’s one-year bar on initiating impeachment proceedings against the same official?
- What is the proper meaning of “initiate” in Article XI, Secs. 3(1) and 3(5), and when are impeachment proceedings deemed initiated?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)