Title
Vargas vs. Rilloraza
Case
G.R. No. L-1612
Decision Date
Feb 26, 1948
Petitioner challenged Section 14 of the People's Court Act, alleging it unconstitutionally added Supreme Court Justice disqualifications. The Court upheld the law, ruling Congress had authority to regulate disqualifications, temporary judicial designations were valid, and no constitutional violations occurred.

Case Digest (G.R. No. L-1612)

Facts:

Jorge B. Vargas v. Emilio Rilloraza, Jose Bernabe, Manuel Escudero, Judges of People's Court, and the Solicitor General, G.R. No. L-1612, February 26, 1948, Supreme Court En Banc, Hilado, J., writing for the Court. Petitioner Jorge B. Vargas, through a defense motion dated August 28, 1947, attacked the constitutionality of Section 14 of the People’s Court Act (Commonwealth Act No. 682), advancing eleven grounds (a–k) that the provision (inter alia) (1) adds qualifications for Supreme Court Justices, (2) authorizes appointment of non‑constitutional Justices, (3) effects removal by other than impeachment, (4) strips the Commission on Appointments of its role, (5) creates a second Supreme Court, (6) impairs rule‑making, (7) is a bill of attainder, (8) denies equal protection, (9) is ex post facto, (10) effects unconstitutional amendment, and (11) permits “packing” and destroys judicial independence.

The Solicitor General opposed the motion, incorporating a substantially similar pleading filed in G.R. No. L-398 (People v. Sison), and argued (summarized) that Congress had the power to enact Section 14; that Section 14 did not amend constitutional qualifications; that the constitutional appointment and confirmation provisions applied to permanent appointees and not to temporary designees; that designation is not a removal; and that Section 14 neither creates a new Supreme Court nor violates equal protection or other constitutional prohibitions. The Solicitor General’s opposition was formally made part of the record by the Court’s October 30, 1947 resolution.

The issues were raised in proceedings before the Supreme Court itself (motions filed and argued before this Court). The Court considered the constitutional provisions implicated (Art. VIII, §§ 2(4), 4–6, 9, 13; Art. XVI, § 2) and the pre‑existing statutory and rule provisions on disqualification (sections 8 and 608 of the old Code of Civil Procedure and Rule 126 of the Rules of Court). After internal deliberation and circulation of opinions, the Court—Hilado, J., for the Court—issued this resolution declaring Section 14 unconstitutional in the respects explained in the body of the opinion and directing...(Subscriber-Only)

Issues:

  • May Congress, consistent with the Constitution, add to the grounds for disqualification of a Justice of the Supreme Court by enacting Section 14 of Commonwealth Act No. 682?
  • May a person who has not been appointed by the President with the consent of the Commission on Appointments act as a Justice of the Supreme Court by virtue of a presidential “designation”?
  • Can the President constitutionally “designate” Judges of First Instance, Judges‑at‑large, or Cadastral Judges to sit temporarily as J...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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