Case Digest (G.R. No. 169777)
Facts:
On July 14, 2006, the Supreme Court sitting en banc resolved six consolidated petitions (G.R. Nos. 169777, 169659, 169660, 169667, 169834, 171246) filed by the Senate of the Philippines, various political parties and party-list organizations (including Bayan Muna, Alternative Law Groups, Inc., PDP-Laban), individual legislators (e.g., Francisco I. Chavez, Jose Anselmo I. Cadiz) and the Integrated Bar of the Philippines, against Executive Secretary Eduardo R. Ermita acting as alter-ego of President Gloria Macapagal-Arroyo. They challenged Executive Order No. 464 which, through Sections 2(b) and 3, required senior executive officials to secure presidential consent before appearing in congressional inquiries, effectively invoking executive privilege. The petitioners sought to compel the appearance of executive officers in inquiries in aid of legislation. After the Court’s April 20, 2006 Decision invalidated the challenged provisions as authorizing a broad implied claim of executiveCase Digest (G.R. No. 169777)
Facts:
- Parties and Consolidated Cases
- Petitioners
- Senate of the Philippines, represented by its officers, and individual senators (G.R. No. 169777)
- Bayan Muna and allied parties (G.R. No. 169659)
- Francisco I. Chavez (G.R. No. 169660)
- Alternative Law Groups, Inc. (G.R. No. 169667)
- PDP-Laban (G.R. No. 169834)
- Jose Anselmo I. Cadiz et al., including the Integrated Bar of the Philippines (G.R. No. 171246)
- Respondents
- Eduardo R. Ermita, Executive Secretary and alter-ego of the President
- Other Executive officials: Secretary of Defense, AFP Chief of Staff, PNP officers
- Background and Procedural History
- Executive Order No. 464 issued by President Gloria Macapagal-Arroyo on December 14, 2005
- Section 1: Prohibition on executive officials’ appearance during question hour
- Section 2(b): Enumeration of “senior officials” covered by executive privilege
- Section 3: Requirement of presidential consent before appearance in inquiries in aid of legislation
- Senate inquiries and refusals
- Executive officials invoked E.O. 464 to decline subpoenas for Senate hearings on alleged misconduct
- Senate petitioners filed petitions for certiorari and prohibition before the Supreme Court
- April 20, 2006 Decision
- Declared Sections 2(b) and 3 of E.O. 464 invalid as authorizing implied claims of executive privilege
- Held E.O. 464 unconstitutional to the extent it barred appearances in aid of legislation without specific invocation of privilege
- Motions for Reconsideration
- Respondents’ Motion (May 18, 2006) challenging the Decision’s treatment of E.O. 464
- PDP-Laban’s Motion (May 17, 2006) contesting the finding on its lack of standing
- Comments filed by all other petitioners endorsing or opposing the motions
Issues:
- Validity of the April 20, 2006 Decision
- Whether the Supreme Court erred in invalidating Sections 2(b) and 3 of E.O. 464 as implied executive privilege
- Whether publication of Senate rules or lack thereof affects the validity of E.O. 464
- Standing of PDP-Laban
- Whether PDP-Laban has the requisite standing to challenge E.O. 464 similarly to Bayan Muna
- Whether PDP-Laban’s status as taxpayers or party members confers a right to sue
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)