Case Digest (G.R. No. 71908)
Facts:
In G.R. No. 71908, decided en banc on February 4, 1986, petitioners—Alberto G. Romulo, Jose B. Laurel, Marcelo B. Fernan and forty-eight other MPs representing more than one-fifth of all members of the Batasan Pambansa—filed on August 13, 1985 Resolution No. 644 and a verified complaint for the impeachment of President Ferdinand E. Marcos. The Speaker of the Batasan referred the papers to the Committee on Justice, Human Rights and Good Government, which on August 14, 1985 dismissed the resolution and complaint as insufficient in form and substance and filed Committee Report No. 154, later noted by the Batasan and archived. On the same day, MP Ramon V. Mitra moved the Batasan to recall the resolution and complaint, but the motion was denied. On September 7, 1985, petitioners brought this original action before the Supreme Court, praying for a writ of prohibition to restrain enforcement of Sections 4, 5, 6 and 8 of the Batasan Rules of Procedure in Impeachment Proceedings (approveCase 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)