Case Digest (G.R. No. L-10520)
Facts:
Lorenzo M. Tanada and Diosdado Macapagal v. Mariano Jesus Cuenco et al., G.R. No. L‑10520. February 28, 1957, the Supreme Court En Banc, Concepcion, J., writing for the Court.Petitioners Lorenzo M. Tanada (Senator; President of the Citizens Party) and Diosdado Macapagal (Member of the House of Representatives and Senate hopeful) challenged the validity of certain nominations and elections to the Senate Electoral Tribunal after the 1955 general elections. Macapagal (with other protestants) had filed an electoral contest (Senate Electoral Case No. 4) against several proclaimed senators; the organization of the Tribunal to hear that contest gave rise to the dispute.
On February 21–22, 1956, the Senate organized the Tribunal. The majority (Nacionalista) nominated and the Senate elected Senators Jose P. Laurel, Fernando Lopez and Cipriano Primicias as three members. Senator Tanada, representing the Citizens Party (admitted to be the party having the second largest number of votes in the Senate), nominated himself as the Citizens Party’s representative but did not nominate two additional Senators. Thereafter Senator Primicias (claiming to speak for the Committee on Rules, and not merely the Nacionalista Party) nominated Senators Mariano Jesus Cuenco and Francisco A. Delgado; the Senate approved those nominations. The Tribunal’s Chairman then appointed technical assistants and private secretaries (Alfredo Cruz, Catalina Cayetano, Manuel Serapio and Placido Reyes), and the Cashier (Fernando Hipolito) was responsible for paying their salaries.
Petitioners filed a petition in the Supreme Court praying for an immediate writ of preliminary injunction and, after hearing, for permanent relief ousting respondents Cuenco and Delgado from acting as members of the Tribunal and restraining payments to the four appointees. Respondents admitted most factual allegations but raised defenses: that the Supreme Court lacked jurisdiction (the matter was not justiciable because the Senate has exclusive power to choose its Tribunal members), that Tanada had waived or exhausted his nomination right, and that the Senate’s action complied with the Constitution’s numeric requirement.
The matter came to the Supreme Court as an original petition seeking injunctive relief and declaration of rights. The Court heard and decided the case on the meri...(Subscriber-Only)
Issues:
- Do the Supreme Court have jurisdiction to entertain petitioners’ challenge to the Senate’s choice of members of the Senate Electoral Tribunal, or is the question a nonjusticiable political question?
- Was the election by the Senate of Senators Mariano J. Cuenco and Francisco A. Delgado as members of the Senate Electoral Tribunal valid?
- Were the appointments of Alfredo Cruz, Catalina Cayetano, Manuel Serapio and Placido Reyes as technical assistants/private secretaries to the purportedly elected members ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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