Martinez v. Morfe
REITERATIONFacts
The Antecedents: Petitioners Manuel Martinez y Festin and Fernando Bautista, Sr., delegates to the Constitutional Convention, sought to invoke parliamentary immunity from arrest. Martinez was facing charges of falsification of a public document, while Bautista was charged with violations of the Revised Election Code. Both argued that their status as delegates, under Republic Act 6132, entitled them to the same immunities as members of Congress, specifically exemption from arrest except for treason, felony, and breach of the peace, as provided by Article VI, Section 15 of the Constitution and Article 145 of the Revised Penal Code. Procedural History: Manuel Martinez y Festin filed a petition for certiorari and habeas corpus after being arrested while en route to a Constitutional Convention session, despite having previously moved to quash the information and warrant of arrest. Fernando Bautista, Sr. filed petitions for certiorari and prohibition after respondent judges denied his motions to quash warrants of arrest issued against him for alleged election code violations. Both petitioners contended that their arrest violated their parliamentary immunity. The Petition: The petitioners sought writs of certiorari to quash the warrants of arrest issued against them. They argued that as delegates to the Constitutional Convention, they were entitled to parliamentary immunity from arrest, as provided by Article VI, Section 15 of the Constitution and further elaborated by Article 145 of the Revised Penal Code. They contended that the offenses for which they were being prosecuted did not fall within the exceptions to this immunity (treason, felony, and breach of the peace). The Solicitor General, representing the respondent judges, argued that the constitutional immunity from arrest was limited to civil cases and did not extend to criminal prosecutions, and that Article 145 of the Revised Penal Code, if interpreted to expand this immunity, was unconstitutional and inoperative.
Issue(s)
Whether the parliamentary immunity of delegates to the Constitutional Convention extends to criminal prosecutions. Whether Article 145 of the Revised Penal Code, which expands parliamentary immunity, is operative despite its potential conflict with the Constitution.
Ruling
The petitions are dismissed. The parliamentary immunity from arrest does not cover treason, felony, and breach of the peace. Article 145 of the Revised Penal Code is inoperative as it is inconsistent with the Constitution.
Ratio Decidendi
On the scope of parliamentary immunity: The Court held that the constitutional provision granting immunity from arrest to members of Congress (and by extension, delegates to the Constitutional Convention) explicitly excepts cases of treason, felony, and breach of the peace. This interpretation is consistent with the historical understanding of parliamentary privilege in both American and English law, which has always excluded criminal offenses from such immunity. The purpose of the immunity is to allow legislators to perform their duties without undue interference, but this does not extend to exempting them from accountability for criminal acts. The phrase "breach of the peace" is understood to encompass all indictable offenses, thereby ensuring that no one is above the law. On the validity of Article 145 of the Revised Penal Code: The Court ruled that Article 145 of the Revised Penal Code, which penalizes public officers for arresting members of Congress except for crimes punishable by a penalty higher than prision mayor, is inoperative. This provision, enacted before the present Constitution, is inconsistent with the explicit command of Article VI, Section 15 of the Constitution, which limits immunity to cases other than treason, felony, and breach of the peace. Citing precedents like People v. Linsangan and De los Santos v. Mallare, the Court reiterated that laws inconsistent with the Constitution become inoperative upon its effectivity. Therefore, the expansion of immunity provided by Article 145 cannot survive the plain language of the Constitution, which prioritizes the maintenance of public order and the accountability of all citizens, including legislators, for criminal offenses.
Main Doctrine
The parliamentary immunity from arrest granted to members of Congress does not extend to cases of treason, felony, and breach of the peace. Article 145 of the Revised Penal Code, which expands this immunity to cover arrests for crimes punishable by less than prision mayor, is inoperative as it is inconsistent with the Constitution.