Title
Vargas vs. Rilloraza
Case
G.R. No. L-1612
Decision Date
Feb 26, 1948
Petitioner challenged Section 14 of the People's Court Act, alleging it unconstitutionally added Supreme Court Justice disqualifications. The Court upheld the law, ruling Congress had authority to regulate disqualifications, temporary judicial designations were valid, and no constitutional violations occurred.

Case Summary (G.R. No. 12287)

Petitioner and Respondent Positions

Petitioner attacked section 14 on eleven grounds (including that it adds qualifications to Supreme Court membership, authorizes appointment without constitutional procedures, effects removal except by impeachment, creates two Supreme Courts, impairs rulemaking power, constitutes a bill of attainder, denies equal protection, and is ex post facto). The Solicitor General opposed the motion, arguing Congress had authority to enact section 14; the provision merely supplements disqualification rules and contemplates temporary designees who need not meet full constitutional appointment qualifications or Commission on Appointments confirmation.

Procedural Posture

The motion to declare section 14 unconstitutional was considered along with a reproduced opposition filed in People v. Sison (G.R. No. L-398) at the Court’s direction. The Court limited the scope of issues it would decide for purposes of the resolution but proceeded to address the central constitutional conflicts raised by section 14.

Statutory Provision at Issue (Section 14, People’s Court Act)

Section 14: (1) disqualifies any Supreme Court Justice who held office under the Philippine Executive Commission or the so-called Philippine Republic from sitting and voting in People’s Court treason cases where the accused held similar positions; and (2) authorizes the President to designate Judges of First Instance, Judges-at-large of First Instance, or Cadastral Judges (without certain disqualifications) to sit temporarily as Justices to form a quorum or until judgment is reached.

Applicable Constitutional Provisions (1935 Commonwealth Constitution)

The Court’s analysis centered on Article VIII (Judicial Department): section 1 (vests judicial power in one Supreme Court and inferior courts), section 4 (composition of Supreme Court — Chief Justice + ten Associate Justices; may sit in banc or in two divisions unless otherwise provided by law), section 5 (appointments by President with consent of the Commission on Appointments), section 6 (qualifications for appointment to the Supreme Court), section 9 (tenure during good behavior until age 70 or incapacity), and section 13 (rules of court). Article XVI, section 2 (continuity of preexisting laws until amended by Congress) and Article IX (impeachment as removal procedure) were also invoked.

Core Legal Questions Presented

(a) May Congress add to pre-existing grounds of disqualification for Supreme Court Justices by statute (section 14)? (b) May persons act as Supreme Court Justices by presidential “designation” without appointment and Commission on Appointments confirmation? (c) Can the President constitutionally designate lower-court judges to sit temporarily as Supreme Court Justices under section 14?

Majority’s Analytical Framework: Constitution Supremacy and Repugnancy Test

The majority applied the principle that legislative acts repugnant to the Constitution cannot become law. Their test compared the operation of the constitutional scheme without section 14 to its operation with section 14 in effect, asking whether section 14 prohibited or impaired duties and powers the Constitution assigns to Supreme Court justices.

Analysis — Congress’ Power to Add Disqualifications (Majority)

The majority concluded that section 14, insofar as it adds a new ground disqualifying constitutional members of the Supreme Court from sitting in specified treason cases, is repugnant to the Constitution. Before section 14, constitutional members had the power and duty to sit in such cases. Section 14’s statutory prohibition prevented those constitutional duties from being performed by constitutionally composed Court; therefore it conflicted with the framing of Article VIII. The majority held that Congress cannot, by statute, impose disqualifications that effectively prevent constitutionally appointed justices from exercising their judicial functions in cases within the Court’s jurisdiction, because such a statute would impair judicial independence and the constitutional allocation of judicial power.

Analysis — Appointment Requirement and “Designation” Versus Constitutional Appointment (Majority)

The majority held that no person not appointed by the President with the consent of the Commission on Appointments (the constitutional method) may act as a Justice of the Supreme Court. The “designation” authorized by section 14 does not satisfy the constitutional appointment-and-confirmation requirement. Designated lower-court judges lack the constitutional vetting and may lack the constitutionally required qualifications (five years’ citizenship, minimum age, ten years’ practice or judgeship). Consequently, designation cannot constitutionally convert a lower-court judge into a Supreme Court Justice, even temporarily.

Analysis — Constitutionality of Presidential Designation of Lower-Court Judges (Majority)

The majority further held that permitting lower-court judges to sit temporarily as Supreme Court Justices by presidential designation creates a constitutional problem because it risks changing the Court’s composition and substituting non-constitutional members in place of those the Constitution prescribes. Even if temporary, such substitution is not authorized by the constitutional provisions governing the composition and appointment of the Supreme Court. The majority rejected the notion that the “unless otherwise provided by law” clause in Article VIII, section 4, authorized alteration of the constitutional composition or mode of appointment; that clause was read as limited to the Court’s manner of sitting (in banc or in two divisions), not to membership qualifications or appointment procedures.

Separation of Powers, Judicial Independence, and “Two Supreme Courts” (Majority)

The majority emphasized that section 14 threatens judicial independence and could result in a de facto “packing” or creation of a second Supreme Court composed partly of designated lower-court judges. Disqualifying constitutional justices and replacing them with designees could change the Court’s character and impair its appellate jurisdiction over capital or life-imprisonment cases, thereby undermining the constitutional scheme of separation of powers and stability of judicial tenure. The majority found such effects intolerable and repugnant to the Constitution.

Holding and Relief

The Court declared section 14 of the People’s Court Act unconstitutional in the respects specified in the opinion and ordered that the case be proceeded with henceforward in harmony with that resolution. Specifically: (a) section 14 is unconstitutional insofar as it disqualifies constitutional members of the Supreme Court and authorizes presidential designation of lower-court judges to sit as temporary Supreme Court Justices in the manner provided; and (b) the proceedings in the case were to proceed consistent with the resolution.

Concurring Opinions (Moran C.J., Perfecto, Briones, et al.)

Chief Justice Moran (concurring) and Justices Perfecto and Briones concurred in the result. Moran emphasized unfairness and the destructive practical effects of section 14 on the Court’s composition and integrity. Perfecto concurred strongly, reiterating the multiple constitutional defects of section 14 (including that it effectively amends the Constitution, violates separation of powers, imperils judicial independence, and permits unconstitutional temporary compositions), and developed an extended exposition of principles protecting constitutional tenure, appointment procedures, immovability, and the danger

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