Title
Romulo vs. Yniguez
Case
G.R. No. 71908
Decision Date
Feb 4, 1986
Petitioners challenged Batasan's dismissal of impeachment complaint against Marcos; SC ruled it a political question, upholding separation of powers and Batasan's exclusive jurisdiction.
impeachment
batasan
committee on justice
A

Case Summary (G.R. No. 71908)

Petitioners

Named petitioners were numerous members of the Batasan Pambansa who, having secured at least one-fifth of the Batasan’s membership, filed Resolution No. 644 and an accompanying verified complaint seeking impeachment of the President and who thereafter challenged the Committee’s and the Batasan’s disposition of that resolution and complaint.

Respondents

Respondents included Nicanor E. Yniguez (Speaker), Manuel M. Garcia, Guardson R. Lood, Renato L. Cayetano, Antonio M. Diaz, Damian V. Aldaba, Juan Ponce Enrile, and other members of the Committee on Justice, Human Rights and Good Government, and the Committee itself. They acted to determine sufficiency and to dismiss the complaint and to report that dismissal, which the Batasan noted and archived.

Key Dates and Procedural Milestones

  • August 13, 1985: Petitioners filed Resolution No. 644 and the verified impeachment complaint with the Batasan; Speaker referred the matter to the Committee on Justice, Human Rights and Good Government.
  • August 14, 1985: The Committee found the complaint insufficient in form and substance, dismissed the complaint, and submitted its report; the Batasan noted the report and sent it to the archives. MP Ramon V. Mitra’s motion to recall the resolution and complaint was denied by the Batasan.
  • September 7, 1985: The present petition was filed with the Supreme Court.
    (Decision rendered by the Supreme Court on February 4, 1986 is relevant to choice of governing Constitution for analysis; the Court relied on the 1973 Constitution in its reasoning.)

Applicable Law (Constitutional Provisions and Rulemaking Authority)

The Court analyzed the dispute under the 1973 Constitution. The relevant constitutional provisions invoked by the parties and the Court included the impeachment clauses (Article XIII, particularly Sections 2 and 3 as interpreted in the decision) and the Batasan’s authority to adopt rules of procedure (Article VIII, Sec. 8(3) under the 1973 Constitution). Petitioners also invoked the Constitution’s amending procedures (Article XVI) in arguing that the Batasan’s rules impermissibly amended the Constitution.

Facts Relevant to the Judicial Challenge

The Committee on Justice determined the complaint was insufficient in form and substance and dismissed it on August 14, 1985; this committee action was noted by the Batasan and archived. Petitioners sought an order from the Supreme Court (prohibition, mandamus, injunction) to (a) declare Sections 4, 5, 6 and 8 of the Batasan’s Impeachment Rules unconstitutional, (b) annul Committee Report No. 154 which dismissed Resolution No. 644 and the attached complaint, and (c) compel the Committee to recall and report out the archived resolution and complaint so that the Batasan could proceed with an impeachment trial.

Procedural History Before the Supreme Court

A related petition (G.R. No. L-71688) filed August 17, 1985 by Arturo M. de Castro and Perfecto L. Cagampang sought certiorari and mandamus to annul the Committee’s dismissal and compel the Committee and the Batasan to give due course to the complaint; that petition was dismissed as raising a political question and falling within the exclusive powers of the Batasan. The present petition was not dismissed outright; respondents were required to comment because petitioners challenged the constitutionality of the Batasan’s Rules, implying that the Batasan might have transgressed constitutional limits, which could raise a justiciable issue.

Relief Sought by Petitioners

Petitioners requested: (1) declaratory relief that Sections 4, 5, 6 and 8 of the Batasan’s Impeachment Rules are unconstitutional; (2) annulment of the Committee’s report dismissing the complaint; (3) preliminary injunction restraining enforcement of the questioned provisions; and (4) a preliminary mandatory injunction (mandamus) compelling the Committee to recall the archived resolution and complaint and report them out so that the impeachment trial could proceed before the Batasan as a body.

Petitioners’ Constitutional Arguments

Petitioners argued that the Batasan Rules (Sections 4, 5, 6 and 8): (a) effectively amended Section 3, Article XIII of the 1973 Constitution by empowering a committee or a smaller body to override an impeachment resolution endorsed by at least one-fifth of Batasan members without complying with the Constitution’s amendatory process; (b) vested the Committee with the power to terminate impeachment proceedings at various stages, usurping the prerogative of the Batasan as a collegiate body; and (c) imposed an unlawful condition precedent in Section 8 by requiring a majority vote of all members of the Batasan to approve a resolution setting forth Articles of Impeachment, whereas the Constitution required only endorsement by at least one-fifth for initiation and prescribed a two-thirds concurrence only for conviction.

Respondents’ Defenses

Respondents’ principal defenses were: (1) the matter concerns the internal proceedings and prerogatives of the Batasan, over which the Court lacks jurisdiction; (2) questions raised are political in nature and nonjusticiable; (3) the Impeachment Rules are consistent with the Constitution; (4) even if the Rules were invalid, the Batasan as a body could dismiss the complaint independent of those Rules; (5) mandamus cannot be directed against a coordinate legislative body to compel performance of duties within its exclusive sphere. Specific respondents also asserted lack of standing by petitioners or reiterated that impeachment powers are exclusively legislative.

Issues Framed by the Court

The Court framed the core issues succinctly: (1) Whether the Supreme Court has jurisdiction to order the Committee to recall and report out the archived impeachment resolution and complaint; (2) Whether, assuming recall, the Court can compel the Batasan to conduct an impeachment trial on the charges; and (3) Whether the challenged Rules (Sections 4, 5, 6 and 8) violate the Constitution’s impeachment provisions.

Court’s Ruling on Jurisdiction and Political Question

The Court concluded it lacked authority to compel the Batasan as a body to conduct the impeachment trial. The dismissal of the impeachment complaint by the Committee was effectively confirmed by the Batasan when it denied MP Mitra’s motion to recall the archived resolution and complaint. That Batasan action was an act of the Batasan as a body in the exercise of constitutional powers. The Court reiterated the separation-of-powers principle: courts will not issue mandamus to a coordinate legislative body to compel performance of duties within that body’s exclusive constitutional sphere. The Court cited precedent (including Alejandrino v. Quezon and Abueva v. Wood) to emphasize that ordering subordinate officers would amount to an order directed effectively to the legislative body itself and would risk unseemly conflict between branches.

Court’s Analysis of the Justiciability of Committee Action

Although petitioners raised constitutional objections to the Rules, the Court treated the essential relief sought as compulsion for the Batasan to proceed to trial. The Court held that even if the order were addressed to the Committee to recall the complaint, such an order would be tantamount to directing the Batasan itself to act and therefore would be ineffectual or improper. The Court emphasized that writs of mandamus and injunction should not be issued where they would be fruitless, cause conflict between branches, or attempt to control the internal deliberations of a legislative body and its committees.

Court’s Analysis of the Constitutionality of the Rules

The Court found no basis to declare Sections 4, 5, 6 and 8 of the Batasan’s Impeachment Rules unconstitutional under the 1973 Constitution. The Court observed that the Constitution prescribes only minimal impeachment parameters—initiation by at least one-fifth of members and conviction by at least two-thirds—but leaves procedural details to the Batasan’s rulemaking power (Article VIII, Sec. 8(3)). Thus the Batasan lawfully adopted rules to determine sufficiency in form and substance, to require evidence and memoranda, to set time frames for committee reports, and to require a majority vote of all members for approval of a resolution setting forth Articles of Impeachment. The Court reasoned that these procedural rules do not amend the Constitution; rather they regulate the preparatory and trial phases and can be adopted, amended, or waived by the Batasan itself.

Court’s Rationale Regarding Section 8 and Majority Dismissal

The Court specifically addressed the argument that Section 8 imposes an unconstitutional condition by requiring a majority vote of all members of the Batasan for approval of the resolution setting forth Articles of Impeachment. The Court found the provision consistent with the Constitution because a dismissal by majority of all members makes it mathematically impossible to achieve the two-thirds vote necessary for conviction; therefore, the Batasan

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