Title
Romulo vs. Yniguez
Case
G.R. No. 71908
Decision Date
Feb 4, 1986
Petitioners challenged Batasan's dismissal of impeachment complaint against Marcos; SC ruled it a political question, upholding separation of powers and Batasan's exclusive jurisdiction.
A

Case Digest (G.R. No. 71908)

Facts:

  • Filing of Impeachment Resolution and Dismissal by Committee
    • On August 13, 1985, petitioners—more than one-fifth of all Batasan Pambansa members—filed Resolution No. 644 and a verified complaint for the impeachment of President Marcos.
    • The Speaker referred the matter to the Committee on Justice, Human Rights and Good Government, which on August 14, 1985 found the complaint “not sufficient in form and substance,” dismissed all charges, submitted its report, and the Batasan noted the report and archived the papers.
  • Motion to Recall and Petition to the Supreme Court
    • Also on August 14, MP Ramon V. Mitra moved that Resolution No. 644 and the complaint be recalled from the archives; the Batasan denied the motion.
    • On September 7, 1985, petitioners filed with the Supreme Court a petition for prohibition, mandamus, and injunction to (a) declare Sections 4, 5, 6, and 8 of the Batasan’s Impeachment Rules and Committee Report No. 154 unconstitutional and void, and (b) compel the Committee to recall and report out the resolution and complaint so that the Batasan could proceed with impeachment.
  • Prior Proceedings and Respondents’ Defenses
    • In G.R. No. L-71688 (filed August 17, 1985), Arturo M. de Castro and Perfecto L. Cagampang sought certiorari and mandamus to annul the same Committee resolution; the Court dismissed that petition as a non-justiciable political question.
    • Respondents (the Speaker, Committee members, and others) argued: lack of jurisdiction; political question doctrine; Impeachment Rules are constitutional; even without those Rules the Batasan could dismiss the complaint; and mandamus cannot compel a coordinate legislative body.

Issues:

  • Whether the Supreme Court has jurisdiction to issue a writ of mandamus or prohibition directing the Batasan Committee to recall from the archives and report out the impeachment resolution and complaint.
  • Whether the Court can compel the Batasan Pambansa as a body to conduct the impeachment trial.
  • Whether Sections 4, 5, 6, and 8 of the Batasan Rules of Procedure in Impeachment Proceedings violate Section 3, Article XIII of the 1973 Constitution—specifically by usurping the collegiate prerogative to impeach and by adding voting requirements not provided by the Constitution.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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