Case Digest (G.R. No. L-1123) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In an original petition filed before the Supreme Court of the Philippines, eight senators, seventeen representatives, and the presidents of the Democratic Alliance, the Popular Front, and the Philippine Youth Party (collectively, Alejo Mabanag et al.) sought a writ of prohibition to restrain enforcement of a joint congressional resolution proposing an amendment to the 1935 Constitution. They named as respondents the three members of the Commission on Elections, the Treasurer of the Philippines, the Auditor General, and the Director of the Bureau of Printing. The petitioners alleged that on September 18, 1946, Congress claimed to have secured the three-fourths affirmative vote required by Article XV, Section 1 of the Constitution to propose an amendment, but had deliberately excluded from the roll three proclaimed and qualified senators and eight representatives who had already taken their oaths and drew their salaries. Had those eleven members been counted, petitioners contended Case Digest (G.R. No. L-1123) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Petition
- Petitioners: eight Senators, seventeen Representatives, and presidents of the Democratic Alliance, Popular Front, and Philippine Youth Party.
- Respondents: Chairman and members of the Commission on Elections, the Treasurer of the Philippines, the Auditor General, and the Director of the Bureau of Printing.
- Relief sought: a writ of prohibition preventing respondents from enforcing a congressional resolution and related Republic Act No. 73 to submit a constitutional amendment to a March 11, 1947 plebiscite.
- Underlying Resolution and Act
- Resolution (Sept. 18, 1946) proposes an ordinance amending Articles XIII and XIV to grant U.S. citizens and enterprises parity with Filipinos in exploiting public lands, natural resources, and public utilities during the 1946–1974 Executive Agreement.
- Republic Act No. 73 calls a plebiscite, fixes March 11, 1947, as the vote date, and appropriates ₱1,000,000 for printing ballots, precinct setup, and other costs.
- Stipulated Election and Membership Facts
- Three Senators (Vera, Diokno, Romero) and eight Representatives were proclaimed elected on April 23, 1946, took oaths (before notaries), drew salaries, and participated in the Speaker/President elections.
- The Senate suspended the three Senators from taking seats pending election protests; the House deferred seating the eight Representatives by referring protests to a committee (no final action).
- Roll-call vote on the resolution: Senate—16 yes, 5 no; House—68 yes, 18 no, 1 abstain, 1 absent.
- Petitioners contend these excluded members properly belong to Congress and, if counted, would have prevented the three-fourths approval required.
Issues:
- Jurisdiction and Political Question
- Does the Supreme Court have jurisdiction to review the validity of a congressional resolution proposing a constitutional amendment?
- Is the amendment process a “political question” beyond judicial review?
- Enrolled Bill Rule and Conclusiveness
- Does the certified enrolled copy of the resolution bind the courts absolutely under the enrolled bill rule?
- Or may courts examine legislative journals to verify compliance with constitutional requirements?
- Substance of Required Vote
- Was the resolution adopted by the constitutionally required three-fourths of all voting members of each House?
- Should the three suspended Senators and eight deferred Representatives be counted as members for purposes of that three-fourths computation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)