Case Summary (G.R. No. L-19823)
Background Facts
On October 27, 1961, former President Garcia appointed Advincula and Avelino to their respective positions. They were qualified for the positions—Advincula on November 2, 1961, and Avelino on October 31, 1961—and assumed their roles shortly thereafter. The Commission on Appointments initially confirmed their appointments on April 27, 1962. However, on April 30, 1962, a member of the Commission submitted a motion for reconsideration, leading to the withdrawal of the confirmation just before the congressional session adjourned on May 17, 1962.
Legal Basis and Issues Raised
The petitioners argued that the reconsideration of their confirmation was null and void under Section 21 of the Revised Rules of the Commission on Appointments. This section stipulates a one-day period within which a motion for reconsideration must be filed post-confirmation. The petitioners contended that since the motion was filed on a day beyond this one-day period, it breached the Rules, rendering any subsequent actions by the Commission invalid.
Proceedings and Debates
During the proceedings, the minutes of the Commission revealed a debate over the interpretation of the “one-day” requirement. Congress members expressed differing opinions regarding whether weekends should be included in this calculation. Some members asserted that filing a motion on April 30 was permissible, as it fell within the next working day post-confirmation on April 27. Others argued that the motion violated the 24-hour requirement due to the intervening non-working days (April 28 and 29).
Court's Reasoning
The court maintained that it could not interfere in the internal procedural matters of a co-equal government branch without infringing upon the principle of separation of powers. The Court underscored that the dispute involved an interpretation of the Commission's own rules rather than a constitutional or legal infraction. The Court also emphasized the discretion granted to the Commission on Appointments to establish its own procedural regulations during sessions.
Conclusion of the Decision
The petition for mandamus lodged by Advincula and Avelino was consequently dismissed due to the inability of the court to adjudicate internal procedural disputes of legislative bodies. The Court directed that the Commission’s interpretation of its own rules prevailed, thus affirming the reconsideration of the confirmation.
Resolution of January 12, 1963
In a subsequent resol
...continue readingCase Syllabus (G.R. No. L-19823)
Case Overview
- This case involves a petition for mandamus filed by Ruperto Advincula and Braulio Avelino, who were ad-interim appointees to the positions of Justices of the Peace in Dao and Ivisan, Capiz.
- The petitioners sought to compel the Secretary of the Commission on Appointments to issue a certification confirming their appointments and to declare the Commission's reconsideration of their confirmation as null and void.
- They also sought to restrain the Department of Justice from enforcing the order for them to vacate their positions.
Factual Background
- Ruperto Advincula and Braulio Avelino received ad-interim appointments from former President Garcia on October 27, 1961.
- Both petitioners qualified for their positions; Advincula on November 2, 1961, and Avelino on October 31, 1961, subsequently assuming their duties.
- On April 27, 1962, the Commission on Appointments favorably considered and confirmed their appointments.
- However, on April 30, 1962, a member of the Commission requested reconsideration of the confirmation due to pending complaints against the petitioners.
- The reconsideration led to the withdrawal of the confirmation, and the appointments were left unacted upon until Congress adjourned on May 17, 1962.
Legal Issues Raised
- The main issue addressed was whether the Commission on Appointments' motion for reconsideration filed three days after the confirmation was valid, given that it was argued to be beyond the one-day limit set by the Commission’s rules.
- The petitioners contended that the re