Romulo v. Yñiguez
REITERATIONFacts
The Antecedents: Petitioners, representing more than one-fifth of the members of the Batasang Pambansa (Batasan), filed Resolution No. 644 calling for the impeachment of President Marcos, along with a verified complaint. The Speaker referred these to the Committee on Justice, Human Rights and Good Government. Procedural History: The Committee found the complaint insufficient in form and substance, disapproved Resolution No. 644, dismissed the charges, and submitted its report to the Batasan, which was noted and sent to the archives. A subsequent motion to recall the resolution and complaint from the archives was also disapproved by the Batasan. The Petition: Petitioners filed a petition for prohibition and mandamus, seeking to restrain respondents from enforcing Sections 4, 5, 6, and 8 of the Batasan Rules of Procedure in Impeachment Proceedings, and to compel the Committee to recall the resolution and complaint from the archives for an impeachment trial. They argued these rules were unconstitutional as they amended the Constitution without following the proper process and usurped the Batasan's power to impeach.
Issue(s)
Whether the Supreme Court has jurisdiction to compel the Batasang Pambansa to proceed with an impeachment trial. Whether Sections 4, 5, 6, and 8 of the Batasan Rules of Procedure in Impeachment Proceedings are unconstitutional. Whether the dismissal of the impeachment complaint by the Committee on Justice, Human Rights and Good Government, and subsequently by the Batasan itself, is subject to judicial review.
Ruling
The petition is dismissed for lack of merit. The Supreme Court held that it cannot compel the Batasang Pambansa to proceed with an impeachment trial, as such matters fall within the political question doctrine and the exclusive domain of the legislative branch. The Court also found no unconstitutionality in the questioned provisions of the Batasan Rules of Procedure for Impeachment Proceedings.
Ratio Decidendi
On the Jurisdiction of the Court and the Political Question Doctrine: The Court reiterated that the 1973 Constitution vested in the Batasang Pambansa the exclusive power to initiate, try, and decide all cases of impeachment. The action of the Batasan Committee in dismissing an impeachment complaint, and the Batasan's subsequent disapproval of a motion to recall such dismissal, involve a political question not cognizable by the Courts. The Court emphasized that it cannot inquire into whether the Batasan acted wisely in exercising its powers, as long as no provision of the Constitution is violated. The interpretation and application of the Batasan's own rules of procedure in impeachment proceedings are beyond the Court's review powers. The powers of the Batasan to dismiss a petition for impeachment it finds not meritorious are discretionary and not subject to judicial compulsion. On the Constitutionality of the Batasan Rules of Procedure in Impeachment: The Court found no unconstitutionality in Sections 4, 5, 6, and 8 of the Batasan Rules of Procedure in Impeachment Proceedings. These rules were promulgated by the Batasan pursuant to its power to adopt rules for its proceedings. The Court clarified that the Constitution only specifies the vote required for initiation (one-fifth of all members) and conviction (two-thirds of all members). The rules providing for dismissal of a complaint for insufficiency in form or substance, lack of sufficient grounds, or absence of probable cause, are not inconsistent with the Constitution. These actions by the Committee are part of the preparatory phase to trial, determining whether the complaint warrants referral to the Batasan for trial, and are not part of the "initiation phase" itself. The dismissal by a majority vote, which makes a two-thirds vote for conviction mathematically impossible, is a valid procedural step. On the Reviewability of the Dismissal and Consummation of Acts: The Court noted that the acts sought to be restrained by prohibition or injunction (the dismissal of the impeachment complaint) had already been consummated. Prohibition or injunction cannot issue to restrain acts already performed. Therefore, even if the rules were found unconstitutional, the remedy would not lie. The doctrine of separation of powers, even in its modified form under the 1973 Constitution, prevents one branch of government from issuing a writ of mandamus to a coordinate branch to compel the performance of duties within the latter's sphere of responsibility. Therefore, the Supreme Court cannot issue a writ of mandamus against the Batasan to compel it to give due course to the impeachment complaint. The Court's intervention would constitute an encroachment upon the legislative branch's domain, which is essential for the safety of the institutions. The Court emphasized that rules of procedure adopted by deliberative bodies like the Batasan are merely procedural and not substantive. They have the nature of by-laws, prescribed for orderly conduct, and are subject to revocation, modification, or waiver at the pleasure of the body adopting them. They do not have the force of public law, and courts generally take no cognizance of their observance or violation. The Batasan's rules on impeachment are within its power to modify or replace, and their observance is not a matter for judicial concern unless they violate the Constitution itself, which was not found to be the case here.
Main Doctrine
The Supreme Court cannot compel the Batasang Pambansa to proceed with an impeachment trial, as the dismissal of an impeachment complaint by the Batasan itself, or by its Committee acting with the Batasan's implicit or explicit approval, involves a political question beyond the Court's jurisdiction. Furthermore, the Batasan has the inherent power to promulgate its own rules of procedure for impeachment proceedings, and the Court will not interfere with the legislative branch's internal rules and deliberations.