Case Summary (G.R. No. L-33517)
Mandamus Petition and Procedural History
On May 19, 1971, the Court adopted a resolution requiring the respondents to file an answer within ten days from notice and to refrain from moving to dismiss the petition. On June 16, 1971, respondents filed an answer and a motion to dismiss. They invoked several grounds, including alleged lack of jurisdiction premised on the separation of powers; absence of a cause of action; lack of legal personality to sue; non-joinder of indispensable parties; and the alleged mischievous consequences that would follow from a suit of that character.
Petitioners filed a reply on June 26, 1971, and respondents filed a rejoinder on June 28, 1971. Respondents also filed a surrejoinder on July 6, 1971, to which petitioners replied the same day. A hearing was set and held on August 4, 1971.
The Governing Development: Mootness and Abolition of the House
The Court declined to resolve the various legal issues raised in the pleadings. It relied instead on the controlling circumstance that rendered the controversy no longer justiciable. The Court held that, consistent with the ruling in Philippine Constitution Association, Inc. vs. Gimenez, the mandamus suit had become moot and academic because of the effectivity of the present Constitution and the consequent abolition of the House of Representatives.
The Court explained that the petition of that nature had already been rendered unnecessary by the constitutional framework then becoming operative. It reasoned that the difficulty raised in such suits would not attend a petition filed after the Constitution’s effectivity because the Constitution then provided a direct rule governing public access and auditing of the National Assembly’s accounts.
Legal Basis and Reasoning
To support its conclusion of mootness, the Court quoted the portion of the earlier ruling in Philippine Constitution Association, Inc. vs. Gimenez that addressed why similar obstacles would not persist under the present constitutional setting. The quoted rationale emphasized a specific constitutional provision: “The records and books of accounts of the National Assembly shall be open to the public in accordance with law, and such books shall be audited by the Commission on Audit which shall publish annually the itemized expenditures for each Member.” The Court cited this as Article VIII, Section 8, par. (2) of the Constitution.
By invoking that provision, the Court t
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Case Syllabus (G.R. No. L-33517)
Parties and Procedural Posture
- Petitioners were Philippine Constitution Association, Salvador Araneta, Juan V. Borra, Jose Nuguid, Jose Nolledo, and Ramon A. Gonzales.
- The petitioners sued as delegates to the 1971 Constitutional Convention, and also as citizens and taxpayers.
- The respondents were Hon. Cornelio T. Villareal in his capacity as Speaker of the House of Representatives, together with the Chief Accountant, House of Representatives, Manila, and the Auditor, House of Representatives, Manila.
- The petitioners filed a mandamus proceeding on May 15, 1971.
- On May 19, 1971, the Court required the respondents to file an answer within ten days and to not move to dismiss.
- On June 16, 1971, the respondents filed an answer and motion to dismiss.
- The parties submitted further pleadings including a reply on June 26, 1971, a rejoinder on June 28, 1971, a surrejoinder on July 6, 1971, and a reply thereto on the same day.
- The hearing occurred on August 4, 1971.
- The Court disposed of the petition without resolving the merits, treating the controversy as moot and academic.
Key Factual Allegations
- The petitioners sought inspection and examination of the books, records, vouchers, and other supporting papers of the House of Representatives.
- The requested documents were said to have relevance to the alleged transfer of P26.2 million from various executive offices to the House of Representatives.
- The petitioners also sought access to the House records dealing with the original outlay of P39 million appropriated for the 1969–1970 fiscal year.
- The petitioners framed the requested inspection as an inquiry into House expenditures and related accounting documentation.
Relief Sought via Mandamus
- The petitioners prayed for the issuance of a writ of mandamus.
- The writ would order the respondents to inspect and examine the House of Representatives books, records, vouchers, and supporting papers.
- The requested inspection extended both to records tied to the alleged transfer of P26.2 million and to records covering the original outlay of P39 million.
Jurisdictional and Substantive Objections
- The respondents argued for dismissal bas