Case Summary (G.R. No. 83216)
Background and Antecedent Facts
On April 6, 1988, the President appointed Teresita Quintos-Deles as a sectoral representative for women, among others, pursuant to Article VII, Section 16 and Article XVIII, Section 7 of the 1987 Philippine Constitution. Although the appointed representatives were scheduled to take their oaths on April 18, 1988, there was opposition from some members of Congress, leading to the suspension of their oathtaking as they were told confirmation by the Commission on Appointments was necessary.
Procedural Developments
In light of the opposition, a letter dated April 11, 1988 was sent by the President to the Commission on Appointments for the confirmation of the sectoral representatives' appointments. Petitioner Quintos-Deles contested the need for confirmation, arguing that previous sectoral representatives were allowed to assume office without such a process. Speaker Ramon V. Mitra Jr. informed the petitioner that jurisdiction over the appointment had passed to the Commission on Appointments after the submission for confirmation.
Legal Arguments Presented by the Petitioner
The central issue raised by petitioner Quintos-Deles is whether her appointment as a sectoral representative requires confirmation by the Commission on Appointments. The position taken by the Solicitor General was that since the President submitted the appointments for confirmation, such confirmation is indeed required.
Commission on Appointments' Position
On August 15, 1988, the Commission on Appointments supported the Solicitor General's position, asserting that the petitioner’s appointment had not been acted upon by the Commission before Congress adjourned, rendering the matter moot. They cited the rules indicating that nominations not acted on by the end of the session shall be returned to the President.
Constitutional Framework
The 1987 Constitution stipulates that the House of Representatives comprises not more than 250 members, with a portion allocated for sectoral representatives. Article VII, Section 16 details the appointments by the President requiring the consent of the Commission on Appointments. It distinguishes the roles and appointments of various officials with specific mention of those that necessitate consent.
Relevant Judicial Precedents
In earlier jurisprudence, particularly the case of Sarmiento vs. Mison, the Supreme Court indicated that only specific appointments detailed in the Constitution require confirmation. The Court affirmed that appointments of the sectoral representatives, while made by the President, fall under the broader category that does require confirmation.
The Court's Opinion
Upon review, the Court concluded that Quintos-De
...continue readingCase Syllabus (G.R. No. 83216)
Introduction
- This case is a special civil action for prohibition and mandamus with injunction.
- The petitioners are seeking to compel the Commission on Appointments to allow Teresita Quintos-Deles to perform her duties as a member of the House of Representatives representing the Women’s Sector.
- The case also seeks to restrain the respondents from subjecting her appointment to the confirmation process.
Antecedent Facts
- On April 6, 1988, Teresita Quintos-Deles and three others were appointed as Sectoral Representatives by the President under Article VII, Section 16, paragraph 2 and Article XVIII, Section 7 of the Constitution.
- The appointments were communicated to Speaker Ramon Mitra, Jr. on the same day.
- Scheduled oaths for the appointees on April 18, 1988, were suspended due to opposition from some congressmen who insisted on confirmation by the Commission on Appointments.
- A subsequent letter from the President on April 11, 1988, submitted the appointments for confirmation.
Legal Contentions
- Petitioner Deles argued that her appointment does not require confirmation by the Commission on Appointments, citing that previous sectoral representatives did not undergo such confirmation.
- Respondents, including the Solicitor General, contended that the submission for confirmation was necessary following the Pr