Case Digest (G.R. No. 78239)
Facts:
The case Jorge B. Vargas v. Emilio Rilloraza, Jose Bernabe, Manuel Escudero, Judges of People’s Court, and the Solicitor General of the Philippines (G.R. No. L-1612, February 26, 1948) arose from a challenge to the constitutionality of Section 14 of the People’s Court Act (Commonwealth Act No. 682). The petitioner, Jorge B. Vargas, assailed Section 14 upon multiple grounds, asserting it violated constitutional provisions relating to the composition, qualifications, appointment, and independence of the Supreme Court. The facts involved a situation where members of the Supreme Court who held office under the Philippine Executive Commission or the government during the Japanese occupation were disqualified from sitting and voting in cases where the accused had also held such positions. The statute further authorized the President to designate judges of lower courts temporarily to sit as Supreme Court Justices in such cases to complete a quorum. The petition contended that this sec
Case Digest (G.R. No. 78239)
Facts:
- Background of the Case
- Counsel for the defense filed a motion dated August 28, 1947, challenging the constitutionality of Section 14 of the People’s Court Act (Commonwealth Act No. 682).
- The grounds for the challenge included that Section 14:
- Added qualifications for Supreme Court members beyond the Constitution.
- Authorized appointment of Supreme Court members lacking constitutional qualifications.
- Removed Supreme Court members other than by impeachment.
- Deprived the Commission on Appointments of its approval role.
- Created two Supreme Courts.
- Impaired the Supreme Court's rule-making power.
- Acted as a Bill of Attainder punishing justices for service during Japanese occupation.
- Denied equal protection of the laws.
- Was an ex post facto law.
- Amended the Constitution by improper procedure.
- Destroyed judicial independence and allowed “packing” of the Supreme Court.
- Opposition by the Solicitor General
- The Solicitor General opposed the motion, asserting that:
- Congress had power to enact Section 14.
- Section 14 did not amend constitutional qualifications or members.
- Constitutional qualifications applied only to permanent appointees, not temporary designees.
- Section 5 of Article VIII on appointments did not apply to temporary designations.
- Section 14 did not remove members but merely disqualified them in specific cases.
- It did not create a second Supreme Court.
- It did not impair the Court’s rule-making powers.
- It was not a Bill of Attainder or ex post facto law.
- It did not deny equal protection or amend the Constitution improperly.
- It did not destroy judicial independence or curtail jurisdiction.
- Constitutional and Legal Provisions Considered
- Article VIII, Sections 4, 5, 6, 9, and 13 of the Philippine Constitution.
- Article XVI, Section 2 on laws remaining in force unless inconsistent with the Constitution.
- Former Code of Civil Procedure sections on disqualification of judges, incorporated into Rules of Court, Rule 126.
- Section 14 of the People’s Court Act provided:
- Justices who held office during Japanese occupation governments are disqualified from sitting in cases involving accused who also held such offices.
- If lack of quorum results from disqualification or other grounds, the President may designate judges of lower courts to sit temporarily as Supreme Court Justices to form a quorum.
Issues:
- Whether Congress had the power to add new grounds for disqualification of Supreme Court Justices by Section 14 of the People’s Court Act.
- Whether a person not appointed and confirmed as Supreme Court Justice pursuant to the Constitution can act temporarily as a Justice by “designation” under Section 14.
- Whether the President’s power under Section 14 to designate lower court judges to temporarily sit as Supreme Court Justices is constitutional.
- Whether Section 14 violates constitutional provisions on:
- Composition and membership qualifications of the Supreme Court.
- The appointment process requiring Commission on Appointments’ consent.
- Judicial independence and security of tenure.
- Prohibition against creating more than one Supreme Court.
- The rule-making power of the Supreme Court.
- Bill of Attainder and equal protection clauses.
- Impeachment as the sole mode of removal of Justices.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)