Case Digest (G.R. No. 160261)
Facts:
Ernesto B. Francisco, Jr. v. The House of Representatives, G.R. Nos. 160261, 160262, 160263, 160277, 160292, 160295, 160310, 160318, 160342, 160343, 160360, 160365, 160370, 160376, 160392, 160397, 160403 and 160405, November 10, 2003, the Supreme Court En Banc, Carpio Morales, J., writing for the Court.On July 22, 2002 the House of Representatives adopted a Resolution directing the House Committee on Justice to investigate the disbursements and expenditures of the Chief Justice from the Judiciary Development Fund (JDF). On June 2, 2003 former President Joseph E. Estrada filed a verified impeachment complaint against Chief Justice Hilario G. Davide, Jr. (and several Associate Justices) which was referred to the House Committee on Justice on August 5, 2003; the Committee found it "sufficient in form" on October 13, 2003 but voted to dismiss it as "insufficient in substance" on October 22, 2003, and a Committee Report had not yet been transmitted to the House in plenary.
On October 23, 2003 Representatives Gilberto C. Teodoro, Jr. and Felix William B. Fuentebella filed a second verified impeachment complaint against Chief Justice Davide; that filing was accompanied by a Resolution of Endorsement signed by at least one‑third of all Members of the House. Petitioners in many separately filed but consolidated actions (lawyers, taxpayers, the Integrated Bar, civic groups, Members of the House, and others) challenged the second complaint and aspects of the House Impeachment Rules adopted November 28, 2001 (particularly Rule V, Sections 16 and 17), principally on the ground that the second complaint violated Article XI, Section 3(5) of the 1987 Constitution ("No impeachment proceedings shall be initiated against the same official more than once within a period of one year").
The petitions (variously seeking certiorari, prohibition, mandamus, injunctions, TROs, and declaratory relief) were consolidated. The Court, without necessarily giving them due course, in its October 28, 2003 resolution consolidated the cases, required comments, set oral arguments for November 5–6, 2003, appointed amici curiae (including former Constitutional Commissioners and legal academics), and directed the parties to maintain the status quo. The House (through Speaker De Venecia) and the Senate (through Senate President Drilon) each filed manifestations contesting jurisdiction or prematurity; Senator Aquilino Pimentel intervened; other motions to intervene were granted. The Court heard amici and counsel on November 5–6. Several Justices offered to recuse; the Court rejected some offers and directed certain temporary inhibitions.
After full briefing and oral argument, the Court addressed threshold questions (judicial r...(Pro-only)
Issues:
- May the Supreme Court exercise judicial review over questions arising from impeachment proceedings, or are such matters non‑justiciable political questions?
- Do petitioners have standing to invoke the Court’s certiorari jurisdiction to challenge the House rules and the second impeachment complaint?
- Are the consolidated petitions ripe or premature for adjudication?
- Are Sections 16 and 17 of Rule V of the House Rules of Procedure in Impeachment Proceedings (approved November 28, 2001) unconstitutional for contravening Article XI, Section 3 of the 1987 Constitution?
- Is the second impeachment complaint filed October 23, 2003 barred under Article XI, Section 3(5...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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