Case Digest (G.R. No. 112090) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1955, Lorenzo M. Tanada, a Citizens Party Senator, and Diosdado Macapagal, a Liberal Party member of the House of Representatives and unsuccessful Senate candidate, became petitioners in an original action before the Supreme Court. They challenged the validity of two Senators’ election to the Senate Electoral Tribunal under Article VI, Section 11 of the 1935 Constitution. On February 22, 1956, after the Nacionalista Party (the majority in the 24-member Senate) nominated and had elected Senators José P. Laurel, Fernando López, and Cipriano Primicias, Senator Tanada—representing the Citizens Party as the party with the second largest number of votes—nominated only himself. Thereafter, Senator Primicias purportedly in the name of the Senate Committee on Rules nominated two more Nacionalista Senators, Mariano J. Cuenco and Francisco A. Delgado, who were then elected by the Senate despite objections from Senators Tanada and Lorenzo Sumulong. Cuenco and Delgado took oaths and began Case Digest (G.R. No. 112090) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Context
- Petitioners
- Lorenzo M. Tanada – Senator, President of the Citizens Party (minority party in Senate)
- Diosdado Macapagal – Representative in House, Liberal Party candidate for Senate in 1955
- Respondents
- Senators Mariano J. Cuenco and Francisco A. Delgado – chosen as members of the Senate Electoral Tribunal
- Their aides: Alfredo Cruz, Catalina Cayetano, Manuel Serapio, Placido Reyes
- Fernando Hipolito – Cashier and Disbursing Officer of the Senate Electoral Tribunal
- Election Contest and Tribunal Organization
- November 1955 general elections: Macapagal contests the election of nine proclaimed senators (Senate Electoral Case No. 4)
- February 22, 1956 Senate session for organizing the Electoral Tribunal
- Majority party (Nacionalista) nominees elected: José P. Laurel, Fernando López, Cipriano Primicias
- Minority party (Citizens Party) nominee elected: Lorenzo M. Tanada
- On behalf of the Committee on Rules (Nacionalista majority), Senators Cuenco and Delgado were then nominated and elected over the objection of Tanada and Senator Sumulong
- Staff Appointments
- As “members” of the Tribunal, Cuenco and Delgado caused appointments of their technical assistants/private secretaries (Cruz, Cayetano, Serapio, Reyes)
- Respondent Hipolito paid their salaries
- Petition for Relief
- Petitioners allege
- The Constitution (Art. VI, Sec. 11) mandates equal representation of majority and second-largest parties in the Electoral Tribunal
- The nomination and election of two additional Nacionalista Senators (Cuenco, Delgado) violated that mandate
- Consequently, those Senators and their staff unlawfully usurp Tribunal offices
- Prayer for relief
- Preliminary injunction restraining respondents from acting as Tribunal members or paying salaries
- Permanent ouster of respondents from those offices
- Respondents’ Answer
- Admit facts except legal allegations of invalidity
- Special defenses
- Lack of judicial power to review Senate’s choice of its Tribunal members
- No cause of action: petitioner Tanada allegedly waived nomination rights; estoppel; remedy lies in public opinion, not courts
Issues:
- Does the Supreme Court have jurisdiction to review the Senate’s acts in organizing its Electoral Tribunal?
- Is the election of Senators Cuenco and Delgado, and the resulting appointments of their aides, valid under Article VI, Section 11 of the Constitution?
- What remedies, if any, should be granted to petitioners?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)