Case Digest (G.R. No. 187883) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. Nos. 187883 and 187910, decided by the Supreme Court En Banc on June 16, 2009 and reported in 607 Phil. 334 (2010), petitioners Atty. Oliver O. Lozano and Atty. Evangeline J. Lozano-Endriano (G.R. No. 187883) and petitioner Louis “Barok” C. Biraogo (G.R. No. 187910) filed separate but consolidated petitions against Speaker Prospero C. Nograles, in his capacity as Speaker of the House of Representatives, Congress of the Philippines. They sought the nullification of House Resolution No. 1109, which “calls upon the Members of Congress to convene for the purpose of considering proposals to amend or revise the Constitution, upon a three-fourths vote of all the Members of Congress.” The petitions, brought directly to the Supreme Court as taxpayers and concerned citizens, aimed to obtain a definitive interpretation of Section 1, Article XVII of the 1987 Constitution. No lower court proceedings preceded these petitions, as they were filed under the Court’s original jurisdiction Case Digest (G.R. No. 187883) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Petitioners: Atty. Oliver O. Lozano and Atty. Evangeline J. Lozano-Endriano; Louis “Barok” C. Biraogo, in their capacities as concerned citizens and taxpayers.
- Respondent: Speaker Prospero C. Nograles, Representative, Majority, House of Representatives.
- Subject Matter
- House Resolution No. 1109, entitled “A Resolution Calling upon the Members of Congress to Convene for the Purpose of Considering Proposals to Amend or Revise the Constitution, Upon a Three-fourths Vote of All the Members of Congress.”
- No actual constitutional convention convened; no proposals or rules adopted; no allocation or disbursement of public funds.
- Procedural History
- Two petitions filed: G.R. No. 187883 and G.R. No. 187910, praying for nullification of HR No. 1109 and for declaratory relief on Section 1, Article XVII of the 1987 Constitution.
- Resolution rendered by the Supreme Court, En Banc, June 16, 2009, dismissing the petitions for lack of justiciability.
Issues:
- Justiciability
- Whether the petitions present an actual case or controversy cognizable by the Court.
- Whether the petitions are ripe for judicial review.
- Standing (Locus Standi)
- Whether petitioners, as taxpayers and citizens, suffered a personal injury or hardship sufficient to confer standing.
- Whether the “transcendental importance” doctrine applies to grant standing.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)