Hilario Davide Jr. v. House of Representatives

Posted Nov 10, 2003

By Anonymous

7 min read

Case Title and Citation

In the matter of impeachment complaints against Chief Justice Hilario G. Davide, Jr.; G.R. Nos. 160261, 160262, 160263, 160277, 160292, 160295, 160310, 160318, 160342, 160343, 160360, 160365, 160370, 160376, 160392, 160397, 160403, 160405; November 10, 2003; Supreme Court - En Banc; Ponente: not stated in the text provided.

Facts

The 12th Congress adopted and published the Rules on Impeachment (House Impeachment Rules) on November 28, 2001, replacing the 11th Congress rules.
On June 2, 2003, a first impeachment complaint was filed against Chief Justice Hilario G. Davide, Jr., and seven associates, for culpable violation of the Constitution, betrayal of public trust, and other high crimes; it was endorsed and referred to the House Committee on Justice.
On October 23, 2003, after the Committee voted to dismiss and prior to plenary action, a second impeachment complaint was filed against Chief Justice Davide, founded on the results of a House legislative inquiry, accompanied by a Resolution of Endorsement signed by at least one-third of all House Members.
Petitioners in G.R. No. 160261 and others challenged the propriety and constitutionality of the second impeachment filing, the validity of the House Rules on impeachment (notably Sections 16 and 17 of Rule V and Sections 5 of Rule III), and sought to prohibit transmission of the Articles of Impeachment to the Senate or to enjoin proceedings.
The petitions asserted that the second impeachment violated the one-year bar in Article XI, Section 3(5) of the 1987 Constitution; that House Rules contravened the Constitution; and that judicial review could and should determine the constitutionality of impeachment-related actions.
The Court consolidated the petitions, heard arguments, and considered whether it had jurisdiction to review impeachment proceedings, whether the House Rules were constitutional, and whether the second impeachment complaint was valid and timely.
The Court ultimately held that (a) Sections 16 and 17 of Rule V are unconstitutional for violating the Constitution; (b) the second impeachment complaint is barred under Article XI, Section 3(5) of the Constitution; (c) the Court has jurisdiction to review impeachments under the expanded certiorari power; (d) standing requirements were satisfied for transcendental public-interest challenges; and (e) the issues presented are not non-justiciable political questions.

Issues

Did the filing of the second impeachment complaint against Chief Justice Davide violate the one-year bar under Article XI, Section 3(5) of the 1987 Constitution?
Are Sections 16 and 17 of Rule V (12th Congress) unconstitutional for violating the Constitution?
Do petitioners have standing to challenge the impeachment proceedings and related House Rules?
May the Supreme Court exercise judicial review over impeachment proceedings, or is the matter a non-justiciable political question?

Ruling

Yes — The second impeachment complaint violated the one-year bar in Article XI, Section 3(5) of the Constitution; once an impeachment proceeding is initiated, another cannot be initiated within one year against the same official.
Yes — Sections 16 and 17 of Rule V are unconstitutional for contravening the Constitution’s initiation and one-year bar provisions; they redefine “initiate” in a manner inconsistent with the constitutional text.
Yes — Petitioners have standing, based on transcendental importance and direct interest in public funds and the integrity of the judiciary; the Court relaxed standing requirements given the public nature of the dispute.
Yes — The Court held that it possesses jurisdiction to review impeachment-related actions under the expanded certiorari power and that the impeachment questions are justiciable, not purely political.

Reasoning / Ratio Decidendi

Judicial Review and Constitutional Framework:
- The Court reaffirmed that the judiciary has a constitutional duty to settle actual controversies involving rights and to determine grave abuses of discretion by any branch or instrumentality, as provided by Article VIII, Section 1 of the 1987 Constitution.
- The decision emphasized that the separation of powers does not permit absolute autonomy among branches; rather, it envisions checks and balances, including judicial review, to prevent grave abuses.
- The Court cited Angara v. Electoral Commission and later cases to support its view that judicial review is an integral and ongoing function, even in impeachment matters, and that not all impeachment issues are non-justiciable.
Initiation and the One-Year Bar:
- The Constitution vests in the House exclusive power to initiate impeachment, but with specific procedural constraints (Sections 3(2)-(5)). The Court interpreted initiation as the filing of a verified impeachment complaint (or its equivalent when endorsed by a citizen or by a majority), and not simply acts within the House proceedings thereafter.
- Because the first impeachment complaint against Davide was filed on June 2, 2003, and the second on October 23, 2003, the second complaint fell within one year of initiation and thus violated the constitutional bar.
Rule 16/17 of the 12th Congress Impeachment Rules:
- The Court held that deeming impeachment proceedings initiated upon House actions (e.g., findings by the Justice Committee or the House’s own action) conflicts with the constitutional meaning of initiation (filing and referral/endorsement). Sections 16 and 17 thus contravene the Constitution.
Standing and Public Interest:
- The Court recognized standing for taxpayers, citizens, and other petitioners where the dispute involves the proper use of public funds and the integrity of the judiciary, especially given the transcendental importance of the issue and the large number of affected interests.
Justiciability and Political Question Doctrine:
- The Court rejected the argument that impeachment is per se non-justiciable; consistent with its previous jurisprudence, it held that questions involving the constitutionality and procedural propriety of impeachment can be reviewed where there are constitutionally defined standards and where grave abuse or lack of jurisdiction is alleged.

Doctrine / Legal Principle

Judicial review is a constitutional duty and a check against grave abuse of discretion by any branch or instrumentality of government.
The Constitution requires courts to interpret and harmonize provisions; no one constitutional provision should defeat another.
Initiation of impeachment proceedings is anchored to the filing of a verified impeachment complaint (or endorsement under specific conditions), not merely to internal House actions deeming initiation.
The one-year bar on initiating impeachment against the same official is a binding constitutional constraint.
Standing in public-right, transcendental, or taxpayer-based challenges is permissible when the issues affect public funds, constitutional rights, or the proper functioning of government.
The impeachment process is justiciable when constitutional boundaries and procedural rules are involved; courts may adjudicate to prevent grave abuses of power.

Disposition

The challenged provisions of the 12th Congress House Impeachment Rules (Sections 16 and 17 of Rule V) are unconstitutional.
The second impeachment complaint against Chief Justice Hilario G. Davide, Jr. is barred under paragraph 5, section 3 of Article XI of the 1987 Constitution.
The petitions are granted to the extent described: the House’s deemed-initiation provisions are invalid, and the second impeachment cannot proceed under the improper framing of initiation and the one-year bar.

Concurring / Dissenting Opinions

The Court noted the existence of multiple concurring and dissenting opinions among Justices, including separate opinions by Justices Bellosillo, Tinga, Puno, Ynares-Santiago, Vitug, Panganiban, Sandoval-Gutierrez, Callejo, Sr., Quisumbing, Carpio, Corona, Azcuna, and Austria-Martinez, among others.
These opinions addressed nuances of standing, the proper scope of judicial review in impeachment, and the proper interpretation of initiation, but did not alter the controlling result that Sections 16 and 17 of Rule V are unconstitutional and that the second impeachment was barred.

Significance / Notes

Establishes that the judiciary has a defined duty to review impeachment-related actions for constitutional compliance, reinforcing the expanded certiorari jurisdiction.
Clarifies that initiation of impeachment proceedings is triggered by filing/endorsement actions, not by later House proceedings, and that the one-year bar is a strict limit.
Declares that House impeachment rules cannot contravene the Constitution, and provides guidance on how impeachment procedures should be reconciled with constitutional constraints.
Confirms standing for taxpayers and other interested parties in high-importance constitutional controversies affecting the public purse and the independence of the judiciary.
Sets a precedent for the courts to adjudicate matters of high public importance concerning impeachment, even when they involve senior judicial officers, reinforcing the balance among the branches of government.

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