Case Digest (G.R. No. 169777)
Facts:
This is Senate of the Philippines, et al., G.R. Nos. 169777, 169659, 169660, 169667, 169834, and 171246, July 14, 2006, the Supreme Court En Banc, Carpio Morales, J., writing for the Court. Petitioners included the Senate of the Philippines (represented by its leaders and numerous senators), Bayan Muna (represented by its party-list representatives and others), Francisco I. Chavez, Alternative Law Groups, Inc., PDP-Laban, and others; respondents were Eduardo R. Ermita in his capacity as Executive Secretary (as alter-ego of the President) and other executive officials. The petitions challenged provisions of Executive Order No. 464 (E.O. 464) that restricted the appearance of certain executive officials before Congress and which, petitioners argued, authorized blanket or implied claims of executive privilege.The consolidated actions reached the Court after the Senate committees had summoned executive officials and several officials invoked E.O. 464 to refuse appearance or to seek presidential consent before testifying; the Senate sought judicial relief. The Court rendered a Decision on April 20, 2006 (the Decision) addressing the validity and application of Sections 1, 2(b) and 3 of E.O. 464 and the standards for invoking executive privilege. Respondents filed a Motion for Reconsideration dated May 18, 2006 asking reversal of the Decision; petitioner PDP-Laban filed its own Motion for Reconsideration dated May 17, 2006 contesting the Court’s finding that it lacked standing (G.R. No. 169834). Petitioners filed comments opposing respondents’ motion and several parties supported denial of PDP-Laban’s motion.
By this July 14, 2006 Resolution the Court (Carpio Morales, J.) denied both Motions for Reconsideration for lack of merit, amended the title of G.R. No. 169777 to include Senator Manuel B. Villar, Jr., and reaffirmed the Decision’s conclusions that the particular E.O. provisions authorizing implied claims of executive privilege were defective as...(Pro-only)
Issues:
- Did PDP-Laban have the requisite standing to maintain its petition in G.R. No. 169834?
- Should the Court grant respondents’ Motion for Reconsideration and reverse or modify the April 20, 2006 Decision invalidating aspects of E.O. 464, including the Court’s ruling that Sections 2(b) and 3 permit an implied claim of executive privilege that is defective (and whether the lack of publication of Senate rules affects E.O. 464’s validity)?
- Should the title of G.R. No. 169777 be a...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)