Francisco, Jr. v. House of Representatives
NEW DOCTRINEFacts
The Antecedents: On June 2, 2003, former President Joseph Estrada filed an impeachment complaint against Chief Justice Hilario G. Davide, Jr. and seven Associate Justices. This first complaint was referred to the House Committee on Justice, which voted to dismiss it on October 22, 2003, for insufficiency in substance. However, the Committee Report had not yet been sent to the House plenary. On October 23, 2003, a second impeachment complaint was filed by Representatives Gilberto Teodoro, Jr. and Felix William Fuentebella against Chief Justice Davide alone, alleging irregularities in the Judiciary Development Fund (JDF). This second complaint was endorsed by at least one-third of the House members. Procedural History: Various petitions for Certiorari, Prohibition, and Mandamus were filed before the Supreme Court by legislators, bar associations, and taxpayers. They sought to prevent the House from transmitting the second complaint to the Senate and to declare the second complaint unconstitutional for violating Article XI, Section 3(5) of the Constitution, which prohibits initiating impeachment proceedings against the same official more than once within a period of one year. The House of Representatives asserted that the Court lacked jurisdiction over impeachment, claiming it was a political question and that the House had the exclusive power to promulgate its own rules. The Petition: s: The consolidated petitions argued that the House Rules of Procedure in Impeachment Proceedings (specifically Rule V, Sections 16 and 17), which defined 'initiation' as the date the Committee finds the complaint sufficient or the House votes on it, were unconstitutional. They contended that under the Constitution, 'initiate' means the filing of the complaint, and thus the second complaint was barred because it was filed within one year of the first complaint.
Issue(s)
Whether the power of judicial review extends to impeachment proceedings. Whether the issues raised are justiciable or political questions. Whether the petitioners have locus standi. Whether Sections 16 and 17 of Rule V of the House Impeachment Rules are unconstitutional. Whether the second impeachment complaint against the Chief Justice is barred by the one-year ban.
Ruling
WHEREFORE, Sections 16 and 17 of Rule V of the Rules of Procedure in Impeachment Proceedings which were approved by the House of Representatives on November 28, 2001 are unconstitutional. Consequently, the second impeachment complaint against Chief Justice Hilario G. Davide, Jr. which was filed by Representatives Gilberto C. Teodoro, Jr. and Felix William B. Fuentebella with the Office of the Secretary General of the House of Representatives on October 23, 2003 is barred under paragraph 5, section 3 of Article XI of the Constitution.
Ratio Decidendi
On Judicial Review: The Court ruled that it has the power of judicial review over impeachment proceedings. Under Article VIII, Section 1 of the 1987 Constitution, judicial power includes the duty to determine whether there has been a grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the government. This 'expanded certiorari jurisdiction' was specifically intended to prevent the judiciary from evading its duty by invoking the political question doctrine, a lesson learned from the martial law era. The Court held that while impeachment is political, it is subject to constitutional limitations (like the one-year bar) which the Court must enforce. On Justiciability vs. Political Question: The Court distinguished between 'truly political questions' (discretionary matters committed to other branches) and justiciable questions (compliance with constitutional limits). The issue of whether the House violated the one-year bar is not a question of wisdom or policy, but a question of legality and constitutional interpretation. Therefore, it is justiciable. The Court distinguished Nixon v. United States, noting that the US Constitution lacks the specific limitations and the expanded judicial power found in the Philippine Constitution. On Locus Standi: The Court relaxed the rules on standing due to the transcendental importance of the issue. It recognized the standing of legislators (whose prerogatives are affected), taxpayers (due to the use of public funds for impeachment), and concerned citizens/bar associations (given the constitutional issues involved). On the Constitutionality of House Rules: The Court declared Sections 16 and 17 of Rule V of the House Impeachment Rules unconstitutional. These rules defined 'initiation' as the date of the Committee vote or House vote. The Court held that this definition contravened the Constitution. Relying on the records of the Constitutional Commission (specifically the amendments by Commissioner Maambong), the Court ruled that 'initiate' in Article XI, Section 3(5) means the filing of the verified complaint and its referral to the Committee on Justice. The House cannot promulgate rules that effectively alter the meaning of the Constitution. On the Validity of the Second Complaint: Applying the correct definition, the first impeachment complaint (Estrada complaint) was 'initiated' on June 2, 2003, when it was filed and subsequently referred to the Committee. Therefore, the second complaint (Teodoro-Fuentebella complaint), filed on October 23, 2003, fell within the one-year prohibitory period. Consequently, the second complaint is constitutionally barred.
Main Doctrine
The term 'initiate' in Article XI, Section 3(5) of the Constitution means the filing of the impeachment complaint coupled with Congress' taking initial action on said complaint (referral to the Committee on Justice). Consequently, once an impeachment complaint has been filed and referred, no other impeachment complaint may be filed against the same official within a period of one year. House Rules that define 'initiation' as the date of the Committee Report or the House vote are unconstitutional for contravening the clear mandate of the fundamental law.