Case Summary (G.R. No. 228357)
Factual Background
On October 9, 1987, the petitioners filed an election contest docketed as SET Case No. 002-87 before the Senate Electoral Tribunal challenging the proclamation of twenty-two LABAN coalition candidates as senators-elect by the Commission on Elections. Several respondents in that contest were sitting members of the Tribunal. Prior to the filing of the motion by petitioners, Senator Rene A.V. Saguisag had filed a Petition to Recuse and a Supplemental Petition to Recuse the Senator-Members of the Tribunal on substantially the same grounds.
Composition of the Tribunal and Related Conduct
At the time, the Tribunal comprised three (3) Justices of the Supreme Court—Senior Associate Justice Pedro L. Yap (Chairman), Associate Justices Andres R. Narvasa and Hugo E. Gutierrez, Jr.—and six (6) Senators: Joseph E. Estrada, Neptali A. Gonzales, Teofisto T. Guingona, Jose Lina, Jr., Mamintal A.J. Tamano and Victor S. Ziga. Senator Joseph E. Estrada later affiliated with the Liberal Party and resigned as the Opposition representative; Senator Juan Ponce Enrile was designated to replace him. Senator Juan Ponce Enrile voluntarily inhibited himself from participating in SET Case No. 002-87 and in another contest, SET Case No. 001-87, because of his personal involvement as a party.
Motion for Disqualification and Preliminary Proceedings
On November 17, 1987, petitioners (except Senator Estrada but including Senator Enrile) filed a Motion for Disqualification or Inhibition of the Senators-Members of the Tribunal on the ground that those Senators were interested parties and thus disqualified from hearing SET Case No. 002-87. Senator Paterno, another respondent, filed comments opposing the motion. The Tribunal received memoranda and heard oral arguments before issuing the Resolutions denying the motion and denying reconsideration on February 12, 1988 and May 27, 1988 respectively.
Petitioners' Contentions and Proposed Rule Amendment
Petitioners argued that considerations of public policy, fair play and due process required disqualification of the six Senator-Members. They asserted that the Tribunal had relied on the doctrine of necessity in denying disqualification and proposed a practicable, constitutionally acceptable alternative: amendment of the Tribunal’s Rules (Section 24) to permit the contest to be decided by only three Members—specifically, the three Justices—when more than four members are disqualified. The proposed proviso would allow the remaining members, if not less than three including one Justice, to adopt resolutions by majority vote with no abstentions.
Respondent Tribunal's Rulings and Rationale
The Senate Electoral Tribunal dismissed the petitions to recuse and denied the motion for disqualification and the motion for reconsideration. The Tribunal reasoned that the Constitution’s provision on the composition of the Electoral Tribunal mandated joint participation by both the judicial and legislative components in deciding senatorial election contests and that the Framers intended a body in which Senators’ peers in that Chamber would be represented.
Supreme Court's Analysis of Constitutional Requirements
The Court examined Art. VI, Sec. 17, 1987 Constitution, which provides that each Electoral Tribunal "shall be composed of nine Members, three of whom shall be Justices of the Supreme Court ... and the remaining six shall be Members of the Senate ... chosen on the basis of proportional representation." The Court interpreted the constitutional design as manifesting an intent that both the judicial and legislative components share the duty and authority to resolve contests relating to election returns and qualifications of Senators. The Court emphasized the two-to-one proportion of Senators to Justices and concluded that this ratio signaled that the legislative component cannot be entirely excluded from decision-making without frustrating constitutional intent.
Rejection of Petitioners' Proposed Rule Amendment and Doctrine of Necessity
The Court rejected petitioners’ proposal to amend the Tribunal’s Rules to permit adjudication by only the three Justices because such a remedy would contravene the plain terms and purpose of the Constitution. The Court held that no rule amendment could lawfully confer upon the three Justices alone the power to adjudicate senatorial election contests that the Constitution assigned to a nine-member Tribunal composed of Senators and Justices. The Court observed that although individual Senator-Members may voluntarily
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Parties and Posture
- The petitioners filed a Special Civil Action for certiorari seeking nullification of the Senate Electoral Tribunal's Resolutions dated February 12, 1988 and May 27, 1988.
- The respondent was the Senate Electoral Tribunal which had denied the petitioners' Motion for Disqualification or Inhibition and denied their Motion for Reconsideration.
- The petitioners sought judicial review in the Supreme Court of the Tribunal's refusal to disqualify or to inhibit six Senator-Members of the Tribunal from participating in an election contest.
Key Facts
- On October 9, 1987 the petitioners filed an election contest docketed as SET Case No. 002-87 against twenty-two candidates of the LABAN coalition who had been proclaimed senators-elect in the May 11, 1987 congressional elections by the Commission on Elections.
- On November 17, 1987 the petitioners, excluding Senator Joseph E. Estrada but including Senator Juan Ponce Enrile who had been designated to replace Senator Estrada, filed a Motion for Disqualification or Inhibition of the Senators-Members of the Tribunal on the ground that those Senators were respondents in SET Case No. 002-87.
- Senator Rene A.V. Saguisag previously filed a Petition to Recuse and a Supplemental Petition to Recuse the same Senators-Members on substantially similar grounds, and Senator Vicente T. Paterno filed comments on these pleadings.
- The Senate Electoral Tribunal heard memoranda and oral arguments before issuing the challenged Resolutions denying disqualification and denying reconsideration.
- Senator Juan Ponce Enrile voluntarily inhibited himself from participating in the hearings and deliberations of the Tribunal in both SET Case No. 002-87 and SET Case No. 001-87 because of his personal involvement as a party.
Procedural History
- The Senate Electoral Tribunal initially denied the petitioners' Motion for Disqualification or Inhibition in a Resolution dated February 12, 1988.
- The Tribunal thereafter denied the petitioners' Motion for Reconsideration in a Resolution dated May 27, 1988.
- The petitioners filed the present Special Civil Action for certiorari in the Supreme Court to annul those Resolutions.
- The Supreme Court resolved the petition by a judgment dismissing the petition for certiorari for lack of merit.
Issues Presented
- Whether the Senate Electoral Tribunal gravely abused its discretion in denying the petitioners' Motion for Disqualification or Inhibition of the Senator-Members.
- Whether the doctrine of necessity or rules amendment could permit the three Supreme Court Justices of the Tribunal to decide SET Case No. 002-87 without participation of Senator-Members.
- Whether an amendment of the Tribunal's rules could validly vest adjudicatory power in fewer than the constitutionally prescribed membership.
Petitioners' Contentions
- The petitioners contended that considerations of public policy, fair play, and due process compelled the mass disqualification or inhibition of the Senator-Members who were respondents in the contest.
- The petitioners argued that the doctri