Case Digest (G.R. No. 193459)
Facts:
Ma. Merceditas N. Gutierrez v. The House of Representatives Committee on Justice, G.R. No. 193459, March 08, 2011, the Supreme Court En Banc, Carpio Morales, J., writing for the Court.Petitioner Ma. Merceditas N. Gutierrez filed a Motion for Reconsideration (dated February 25, 2011) of the Court's Decision of February 15, 2011, which had resolved issues arising from impeachment complaints against her and questions about the House Committee on Justice's handling of those complaints. Respondents included the House of Representatives Committee on Justice and various intervenors who supported the Committee's actions. The present resolution is the Court's disposition of that Motion.
In the underlying proceedings (summarized in the February 15, 2011 Decision), two separate impeachment complaints against petitioner were filed and were referred to the Committee at different times. The Court had applied the rule in Francisco, Jr. v. The House of Representatives (460 Phil. 830 (2003)) to hold that the initiation of impeachment proceedings is defined by a filing-and-referral sequence, and that the one-year bar on initiating impeachment proceedings against the same official is reckoned from that initiation. The February 15 Decision also lifted a prior Status Quo Ante Order issued September 14, 2010.
In the Motion for Reconsideration petitioner principally contended that (a) the Court deviated from Francisco by treating referral (rather than filing) as material to initiation and to the one-year bar; (b) the House's Impeachment Rules must be published (promulgation = publication) to be effective, citing Commonwealth Act No. 638, Civil Code Article 2, and the Taada v. Tuvera decisions; and (c) alleged bias and procedural unfairness by the Committee chair (Rep. Niel Tupas, Jr.) warranted different relief. Petitioner also urged that lifting the Status Quo Ante Order should not have been made effective immediately while a reconsideration motion was pending.
The Court, upon examining the Motion, found no substantial reason to reconsider its February 15 Decision, reaffirmed and applied the Francisco filing-and-referral doctrine to the present facts, held that "...(Pro-only)
Issues:
- Did the Court err in reaffirming that the initiation of impeachment proceedings is completed by filing and referral (and thus in counting the one-year bar from that point) rather than from mere filing alone?
- Does the constitutional term "promulgate" in Article XI, Section 3 require publication (in the Official Gazette or a newspaper of general circulation) of the House's Impeachment Rules for them to be effective?
- Was the Court required to keep the Status Quo Ante Order in place (i.e., delay lifting it) while petitioner's Motion for Reconsideration was pending, and did allegations of bias require the Court to inte...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)