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G.R. No. 160261 - Francisco, Jr. vs. House of Representatives
Title
Francisco, Jr. vs. House of Representatives
Case
G.R. No. 160261
Decision Date
Nov 10, 2003
Supreme Court ruled House Rules allowing multiple impeachment complaints within a year
unconstitutional, barring second complaint against Chief Justice Davide under the one-year rule.
Jur.ph - Case Summary (G.R. No. 160261)
Constitutional Crisis and Judicial Review
The Court addresses the potential for a constitutional crisis arising from the conflict
between the legislative and judicial branches regarding impeachment proceedings. It
emphasizes that the Constitution provides mechanisms for resolving disputes over
the powers of government branches, asserting that the judiciary has the duty to
interpret the Constitution and ensure adherence to its provisions.
The Constitution has mechanisms to resolve conflicts between branches of
government.
The judiciary's role is to interpret the Constitution and ensure compliance.
The current controversy involves the impeachment of Chief Justice Hilario G.
Davide, Jr.
Separation of Powers and Checks and Balances
The Court reiterates the importance of the separation of powers and checks and
balances among the legislative, executive, and judicial branches. It highlights that
while each branch has autonomy, they must operate interdependently to serve the
public interest.
The separation of powers is fundamental to the governance structure.
Each branch has distinct functions but must coordinate for effective governance.
The Constitution mandates a relationship of interdependence among branches.
Article XI of the 1987 Constitution
Article XI outlines the accountability of public officers, stating that public office is a
public trust and detailing the impeachment process. It specifies the grounds for
impeachment and the procedures for initiating and trying impeachment cases.
Public office is a public trust, and public officials must be accountable.
Impeachment is the process for removing officials for specific offenses.
The House of Representatives has the exclusive power to initiate impeachment.
House Impeachment Rules and Constitutional Compliance
https://jur.ph/jurisprudence/summary/francisco-jr-v-house-of-representatives#_
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1/27/25, 1:36 AM
G.R. No. 160261 - Francisco, Jr. vs. House of Representatives
The House of Representatives adopted new impeachment rules that deviate from the
Constitution's provisions, particularly regarding the initiation of impeachment
proceedings. The Court finds that these rules are unconstitutional as they conflict
with the one-year bar on initiating impeachment against the same official.
The House Rules on Impeachment conflict with the Constitution.
The term "initiate" in the Constitution means to file a complaint.
The new rules allow for multiple complaints within a year, violating
constitutional intent.
First Impeachment Complaint and Its Dismissal
The first impeachment complaint against Chief Justice Davide was filed on June 2,
2003, and dismissed for insufficiency on October 22, 2003. The second complaint
was filed on October 23, 2003, which raised questions about its constitutionality due
to the one-year bar.
The first complaint was filed and subsequently dismissed.
The second complaint was filed within one year of the first.
The timing of the second complaint raises constitutional issues.
Justiciability and Locus Standi
The Court affirms that the petitions are justiciable, meaning they can be adjudicated
in court. It also recognizes the standing of the petitioners, including citizens and
members of Congress, to challenge the impeachment process based on their interest
in upholding constitutional provisions.
The petitions present justiciable issues regarding impeachment.
Petitioners have standing due to their interest in constitutional compliance.
The Court has the authority to review the actions of Congress regarding
impeachment.
Judicial Restraint and Political Questions
The Court discusses the concept of judicial restraint, emphasizing that while it
respects the legislative process, it cannot shy away from its duty to uphold the
Constit...continue reading
Non-Application of the Political Question Doctrine - The issue of whether the House
Rules comply with the Constitution is a legal question, not a political one. The Court
has the duty to interpret the Constitution and to resolve conflicts between the branches
of government when such conflicts arise from constitutional provisions.
Dismissal Without Prejudice- The Court ruled that the second impeachment complaint
should be dismissed without prejudice to its re-filing after the lapse of one year from
the filing of the first impeachment complaint. This ensures that the constitutional oneyear bar rule is respected while preserving the House's exclusive power to initiate
impeachment proceedings.
https://jur.ph/jurisprudence/summary/francisco-jr-v-house-of-representatives#_
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