G.R. No. L-17144 - Osmena, Jr. vs. Pendatun

Petitioner: Congressman Sergio Osmena, Jr., filed on July 14, 1960 a verified petition for declaratory relief, certiorari, prohibition, and preliminary injunction seeking annulment of House Resolution No. 59 and to enjoin its Special Committee from requiring him to substantiate his charges.
Respondents: Salipada K. Pendatun and fourteen other Members of the Special Committee created by House Resolution No. 59.

On June 23, 1960, Osmena delivered a privilege speech entitled “A Message to Garcia,” alleging that under the President’s administration government favors—pardons, bail, and other “free things”—were being sold at premium prices.
On July 8, 1960, the House adopted Resolution No. 59 creating a Special Committee of fifteen Members to investigate the truth of his charges, to summon Osmena for proof, to issue subpoenas duces tecum, and to require him to show cause why he should not be punished if he failed to substantiate.
House Rule XVII, Section 7 provided that a Member shall not be held to answer or be subject to censure for words spoken in debate if further debate or other business has intervened.

The Supreme Court required respondents to answer but issued no preliminary injunction; the Special Committee nevertheless held hearings, found Osmena guilty of serious disorderly behavior, and reported on July 18, 1960.
On July 18, 1960, the House approved Resolution No. 175 suspending Osmena from office for fifteen months for “serious disorderly behaviour.”
On July 19, 1960, respondents filed their answer challenging the Court’s jurisdiction and noting that the Special Committee ceased to exist upon adjournment.

Whether House Resolution No. 59 and the ensuing proceedings infringed Osmena’s absolute parliamentary immunity under Article VI, Section 15 of the Constitution.
Whether the statements in Osmena’s privilege speech constituted disorderly behavior justifying internal discipline.
Whether intervening business under House Rule XVII, Section 7 barred the House from disciplining Osmena for his speech.
Whether the Constitution empowers Congress to suspend one of its Members.