Case Digest (G.R. No. 193459)
Facts:
Gutierrez v. House Committee on Justice, G.R. No. 193459, February 15, 2011, the Supreme Court En Banc, Carpio Morales, J., writing for the Court. Petitioner is Ma. Merceditas N. Gutierrez, Ombudsman; respondents are the House of Representatives Committee on Justice (public respondent) and the private complainants who filed two separate impeachment complaints: the Baraquel group (Risa Hontiveros‑Baraquel, Danilo Lim, Felipe and Evelyn Pestano) and the Reyes group (Renato Reyes, Mother Mary John Mananzan, Danilo Ramos, Edre Olalia, Ferdinand Gaite, James Terry Ridon); Feliciano Belmonte, Jr. appeared as intervenor‑respondent (Speaker).The Baraquel group filed a verified impeachment complaint against petitioner on July 22, 2010 (endorsed by Party‑List Representatives Arlene Bag‑ao and Walden Bello). After the 15th Congress opened on July 26, 2010, the Secretary General transmitted that complaint to Speaker Belmonte on July 27; by Memorandum of August 2 the complaint was directed to be included in the Order of Business. On August 3, 2010 the Reyes group filed a second verified impeachment complaint (endorsed by several party‑list representatives). The Rules of Procedure in Impeachment Proceedings of the 14th Congress were provisionally adopted by the House on August 3, 2010.
On August 11, 2010 the House plenary read and referred both complaints to the Committee on Justice. The Committee, by Resolution of September 1, 2010, found both complaints sufficient in form. The Impeachment Rules of the 15th Congress were published on September 2, 2010. The Committee, by Resolution of September 7, 2010, found both complaints sufficient in substance and directed petitioner to file an answer within ten days. Petitioner sought to file a motion for reconsideration of the Committee’s finding of sufficiency of form; the Committee refused to accept it as premature.
On September 13, 2010 petitioner filed a petition for certiorari and prohibition with application for injunctive reliefs in this Court (procedural vehicle: Rule 65 writs invoking the Court’s expanded certiorari jurisdiction). On September 14, 2010 the Court En Banc resolved to issue a status quo ante order and required respondents to comment; the Court later directed the OSG to file a comment. Oral arguments were held October 5 and 12, 2010. The House Committee on Justice, the Baraquel and Reyes complainants, and the Speaker filed memoranda; the Court en banc rendered its decision on February 15, 2011.
Lower‑forum dispositions relevant here: the Committee on Justice (public respondent) issued the challenged Resol...(Pro-only)
Issues:
- Are the remedies of certiorari and prohibition proper to review the actions of the House Committee on Justice (i.e., is judicial review justiciable here)?
- Is the petition ripe or premature given that the Committee had only reached findings of sufficiency of form and substance?
- Did the Committee’s proceedings and votes deny the petitioner due process (bias of the chair, undue haste, lack of duly promulgated impeachment rules)?
- Did the simultaneous referral and simultaneous action on the two complaints violate Article XI, Section 3(5) of the Constitution’s one‑year bar (i.e., were the second complaint and its referral constitutionally barred)?
- Did the Committee improperly apply or ignore its own Impeachment Rules and the Rules of Criminal Procedure (e.g., duplicity/one‑offens...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)