Title
Tanada vs. Cuenco
Case
G.R. No. L-10520
Decision Date
Feb 28, 1957
Senators Tañada and Macapagal challenged the Senate Electoral Tribunal's formation, alleging constitutional violations in member nominations. The Supreme Court ruled the election of Cuenco and Delgado unconstitutional, upholding the mandatory nomination process by majority and minority parties.

Case Summary (G.R. No. L-10520)

Petition and Relief Sought

Petitioners allege that after Tanada nominated only himself on behalf of the Citizens Party, the Senate improperly allowed the Nacionalista leadership (via its Committee on Rules) to nominate and elect Senators Cuenco and Delgado to the Tribunal. They claim these acts violated Article VI, Section 11, usurped their constitutional rights, and threatened to distort the pending Senate Electoral Case No. 4. They pray for:

  1. A preliminary injunction restraining the respondents from acting as Tribunal members or receiving salaries for aides.
  2. A permanent injunction ousting them from office.

Respondents’ Main Defenses

  • Lack of judicial power to review the Senate’s choice of its Electoral Tribunal members.
  • The petition fails to state a cause of action, asserting Tanada waived his right to nominate two additional members by nominating only himself.
  • The Constitution’s use of “shall” regarding the number of Tribunal members is mandatory, whereas nomination method is directory.

Jurisdiction and Justiciability

The Court held it has jurisdiction to inquire into the constitutionality of the Senate’s actions. The Senate Electoral Tribunal is not a mere internal Senate matter; its members exercise quasi-judicial power over election contests. Judicial review extends to whether the Senate complied with the Constitution’s procedure for selecting those members, as such compliance is essential to preserve the Tribunal’s non-partisan character.

Interpretation of Article VI, Section 11

  • The nine-member composition and the nomination procedure form a single mandatory scheme designed to ensure equal party representation checked by three Supreme Court Justices.
  • The framers created this structure to avoid partisan domination of election contests.
  • The clause prescribing three nominees per party is equally mandatory as the clause fixing total membership.

Analysis of Senate Proceedings

  • Tanada formally objected when the Nacionalista floor nominated Cuenco and Delgado after Tanada had nominated only himself.
  • Debate confirmed universal recognition in the Senate that the Citizens Party held the second-largest vote block and therefore exclusively possessed the right to nominate three members.
  • The Senate’s acceptance of the Committee on Rules’ nomination violated the constitutional scheme by granting the majority party five seats on the Tribunal.

Validity of Appointments of Aides

Although Cruz, Cayetano, Serapio, and Reyes were recommended by de facto members, their appointments by the Tribunal’s Chairman fell within the internal per

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