Case Summary (G.R. No. 160261)
Applicable Constitutional Provisions
1987 Constitution, Article XI, Sec. 2–3 – impeachment grounds (CJO, treason, bribery, graft, other high crimes, betrayal of public trust) and process:
• Sec. 3(1) – House has exclusive power to initiate impeachment.
• Sec. 3(5) – “No impeachment proceedings shall be initiated against the same official more than once within a period of one year.”
• Sec. 3(6) – Senate has sole power to try and decide impeachment cases.
1987 Constitution, Article VIII, Sec. 1 – judicial power includes duty “to determine whether or not there has been a grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the government.”
Procedural Background
• June 2 2003: former President Estrada files first impeachment complaint against Chief Justice Davide and seven colleagues.
• October 22 2003: House Committee on Justice finds first complaint sufficient in form but dismisses it as insufficient in substance; report pending in plenary.
• October 23 2003: Representatives Teodoro and Fuentebella file second impeachment complaint against Chief Justice Davide, endorsed by at least one-third of House members.
• October 28 2003: Supreme Court consolidates and requires comments; en banc sets oral argument; issues status quo order.
• November 5–6 2003: oral arguments and amici curiae presentations.
Issues for Determination
- Locus standi – whether petitioners have legal interest to invoke judicial review.
- Justiciability and jurisdiction – whether impeachment-related acts are subject to Supreme Court review or are nonjusticiable political questions.
- Procedural maturity – whether petitions are premature or ripe for adjudication.
- Interpretation of “initiate” in Article XI, Sec. 3(1) and Sec. 3(5) – what constitutes the start of an impeachment proceeding.
- Constitutionality of Rule V, Sections 16–17 (House Impeachment Rules) – whether they violate the one-year bar provision.
- Validity of the second impeachment complaint – whether it is barred under the constitutional time bar.
Judicial Power, Justiciability and Political Questions
• Article VIII, Sec. 1 empowers courts to settle controversies and to check grave abuses of discretion by any branch.
• Judicial review is not a question of branch superiority but of upholding Constitutional supremacy.
• "Political question doctrine" does not bar review when the Constitution itself lays down limitations on legislative or executive powers.
• Precedents (Angara v. Electoral Commission, Avelino v. Cuenco, TaAada v. Cuenco, Tatad v. Angara, Bondoc v. Pineda) confirm that acts of Congress contravening explicit constitutional limits are subject to judicial review.
Statutory Construction of “Initiate”
• “Initiate” in common usage means to begin or commence – perform or facilitate the first action.
• Constitutional Convention records and contemporaneous amendments (Maambong’s proposal) clarify that the "initiation" of an impeachment proceeding occurs with the filing and referral of the verified complaint to the Committee on Justice, rather than with later steps on the House floor.
House Impeachment Rules vs. Constitutional Time Bar
• 2001 Impeachment Rules (Rule V, Secs. 16–17) “deem” proceedings initiated only upon Committee sufficiency finding, floor vote overturn/affirm or filing by one-third of Members with the Secretary-General.
• These provisions contradict Article XI, Sec. 3(5), which bars any second impeachment "initiated" within one year – understood as
Case Syllabus (G.R. No. 160261)
Facts and Background
- On June 2, 2003 former President Joseph E. Estrada filed the first verified complaint for impeachment against Chief Justice Hilario G. Davide, Jr. and seven Associate Justices of the Supreme Court, alleging culpable violation of the Constitution, betrayal of public trust and other high crimes.
- The first complaint was endorsed by three members of the House of Representatives and referred to the House Committee on Justice.
- On October 13, 2003 the Committee on Justice found the first complaint sufficient in form; on October 22, 2003 it voted to dismiss it for insufficiency in substance.
- On October 23, 2003 Representatives Gilberto C. Teodoro, Jr. and Felix William B. Fuentebella filed a second verified complaint for impeachment solely against Chief Justice Davide, charging irregular use of the Judiciary Development Fund (JDF).
- Accompanying the second complaint was a Resolution of Endorsement signed by at least one-third of all Members of the House.
- The House included the second complaint in its Order of Business but adjourned for lack of quorum before voting to transmit it to the Senate.
Procedural History
- Between October 27 and November 5, 2003, eighteen petitions for certiorari, prohibition, mandamus or injunction were filed in the Supreme Court by citizens, taxpayers, lawyers, members of the House, and civic organizations.
- Petitioners challenged:
• Rule V (Sec. 16 and 17) of the 2001 House Rules of Procedure in Impeachment Proceedings as unconstitutional; and
• Filing the second impeachment complaint within one year of the first, in violation of Article XI, Section 3(5) of the Constitution. - On October 28, 2003 the Supreme Court, without granting due course, issued a status-quo order enjoining the House and the Senate from transmitting or acting on the second impeachment complaint.
- The House and the Senate, and intervenor Senator Pimentel, all filed manifestations or motions asserting lack of jurisdiction, non-justiciability, and prematurity.
- The Court consolidated the petitions, appointed amici curiae, and heard oral argument on November 5–6, 2003.
Constitutional Provisions Involved
- Article II, Section 1: Sovereignty resides in the people; all government authority emanates from them.
- Article VIII, Section 1: Judicial power includes the duty to settle actual controversies and to determine grave abuse of discretion by any branch or instrumentality of government.
- Article XI, Section 2: Lists impeachable officers and grounds for impeachment.
- Article XI, Section 3:
(1) Grants the House of Representatives the exclusive power to initiate all cases of impeachment.
(2) Establishes how impeachment complaints are filed and processed by the House Committee on Justice.
(3) Prescribes the vote of one-third of all Members to affirm or override committee resolutions.
(4) Provides that a complaint or resolution filed by at least one-third of all Members constitutes articles of impeachment.
(5) Bars initiation of impeachment proceedings against the same official more than once within one year.
(6) Grants the Senate the sole power to try and decide all impeachment cases.
(7) Limits judgment to removal and disqualif