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SEN. MIRIAM DEFENSOR SANTIAGO v. SEN. TEOFISTO T. GUINGONA

FACTS:

Senators Miriam Defensor Santiago and Francisco S. Tatad filed a petition seeking the ouster of Senator Teofisto T. Guingona Jr. as minority leader of the Senate and the declaration of Senator Tatad as the rightful minority leader. They claimed that Senator Guingona was unlawfully holding the position, which they believed should belong to Senator Tatad.

The composition of the Senate at that time was 10 members from LAMP, 7 members from Lakas-NUCD-UMDP, 1 member from LP, 1 member from Aksyon Demokrasya, 1 member from PRP, 1 member from Gabay Bayan, and 2 independent members. Senator Marcelo B. Fernan was elected as Senate President, Senator Blas F. Ople as president pro tempore, and Senator Franklin M. Drilon as majority leader.

Senator Tatad, with the agreement of Senator Santiago, assumed the position of minority leader by claiming that only those who voted for Senator Fernan belonged to the "majority," while those who voted for him belonged to the "minority." However, it was revealed that the seven senators from Lakas-NUCD-UMDP had chosen Senator Guingona as the minority leader. The Senate recognized Senator Guingona as the minority leader based on a letter signed by the Lakas-NUCD-UMDP senators.

Senators Santiago and Tatad then filed a petition before the Supreme Court, asserting that Senator Guingona had unlawfully held and exercised the position of Senate minority leader.

The Court formulated the following issues for resolution: 1) Does the Court have jurisdiction over the petition? 2) Was there an actual violation of the Constitution? 3) Was Senator Guingona usurping the position of minority leader? 4. Did Senator Fernan act with grave abuse of discretion in recognizing Senator Guingona as the minority leader?

After considering the arguments and pleadings, the Court found no constitutional or legal infirmity and no grave abuse of discretion in the recognition of Senator Guingona as the minority leader.

The petitioners argue that the issue of who is the lawful Senate minority leader is a matter of constitutional interpretation and therefore within the jurisdiction of the Court. The respondents, on the other hand, argue that the issue is an internal matter of the legislature and that the Court cannot exercise jurisdiction over it. The Court reviewed previous cases, including Avelino v. Cuenco, which upheld the Court's jurisdiction over political questions that involve the interpretation or application of the Constitution or the law.

This partial digest does not provide specific facts about a particular case. Instead, it includes excerpts from various cases to explain the concept of justiciability and the scope of judicial power in the Philippine Constitution. The excerpts highlight the principle of separation of powers and the authority of the courts to determine the legality and validity of acts by the political departments. The 1987 Constitution explicitly defines the scope of judicial power and includes the duty of the courts to settle actual controversies and determine the existence of grave abuse of discretion by any branch or instrumentality of the government. The cases of Daza v. Singson, Coseteng v. Mitra Jr., and Guingona Jr. v. Gonzales are mentioned as examples of the Court's resolution of issues involving the acts of political leaders.

ISSUES:

  1. Whether the Court has jurisdiction to settle the issue regarding the selection of the Senate minority leader.

  2. Whether or not the Senate or its officials violated the Constitution or gravely abused their discretion in recognizing Guingona as the Senate minority leader.

  3. Whether or not the interpretation of petitioners regarding the concepts of "majority" and "minority" in relation to the election of the Senate President and the selection of the minority leader is supported by the Constitution, laws, Senate Rules, or Senate practices.

  4. Whether the Supreme Court has jurisdiction to intervene in the internal affairs of the Senate with regard to the creation and selection of officers.

  5. Whether the creation and selection of the positions of majority and minority leaders in the Senate is a matter within the discretion of Congress.

  6. Whether the petitioners have sufficient proof of a clear and indubitable franchise to the office of the Senate minority leader.

  7. Whether Respondent Guingona's assumption and exercise of the powers of the office of Senate minority leader were illegal or irregular.

  8. Whether Respondent Fernan gravely abused his discretion as Senate President in recognizing Respondent Guingona as the minority leader.

RULING:

  1. Yes, the Court has jurisdiction over the petition. Jurisdiction over the subject matter of a case is determined by the allegations of the petition, and based on the allegations of the petitioners, the Court has jurisdiction.

  2. The interpretation proposed by the petitioners, which asserts that the "majority" in the Constitution refers to senators who voted for the winning Senate President and accepted committee chairmanships, and that the "minority" comprises those who voted for the losing nominee and accepted no such chairmanships, find no clear support from the Constitution, laws, Senate Rules, or Senate practices.

  3. The Constitution does not provide that the members who do not vote for the Senate President automatically constitute the "minority" and have the right to elect the minority leader. The determination of who will be the "majority" and "minority" rests on the political party or faction with the larger number of votes or adherents and the smaller number of votes or adherents, respectively. In a multi-party system like the Philippines, where there could be several minority parties, it is not clear which group has the right to select the minority leader. This determination is left to the Senate itself as it has the power to determine its rules and methods of selecting officers.

  4. The Supreme Court does not have jurisdiction to intervene in the internal affairs of the Senate. The Court cannot direct Congress on how to do its work, and it is not within the province of the courts to intervene in the internal workings of the legislature. The Court must respect the separation of powers and allow Congress to determine its own internal rules and procedures.

  5. The creation and selection of the positions of majority and minority leaders in the Senate is within the discretion of Congress. While there are no specific constitutional or statutory guidelines or rules for these positions, they exist by tradition and long practice. The Court cannot interfere in the legislative process and unilaterally intrude into the exclusive realm of Congress. To do so would be a breach of the constitutional doctrine of separation of powers.

  6. The Supreme Court dismissed the petition, ruling that the petitioners failed to present sufficient proof of a clear and indubitable franchise to the office of the Senate minority leader. The Court also held that Respondent Guingona's assumption and exercise of the powers of the office were not illegal or irregular. Additionally, the Court found that Respondent Fernan did not gravely abuse his discretion as Senate President in recognizing Respondent Guingona as the minority leader.

PRINCIPLES:

  • The Court has the authority to determine the validity of the acts of the political departments of government.

  • Jurisdiction over the subject matter of a case is determined by the allegations of the complaint or petition.

  • The Court will not review the wisdom, merits, or propriety of an action by the political departments, and will only strike it down if it is unconstitutional, illegal, or involves grave abuse of discretion.

  • The interpretation of the terms "majority" and "minority" in relation to the election of the Senate President and the selection of the minority leader is not explicitly defined in the Constitution, laws, Senate Rules, or Senate practices.

  • The Constitution empowers each house of Congress to determine the rules of its proceedings, including the selection of officers.

  • The determination of who constitutes the "majority" and "minority" rests on the political party or faction with the larger number of votes or adherents and the smaller number of votes or adherents, respectively. In a multi-party system, it is not clear which group has the right to select the minority leader.

  • Separation of powers: The courts cannot direct Congress on how to do its work or intervene in the internal affairs of the legislature.

  • Legislative rules: Legislative rules are subject to revocation, modification, or waiver by the legislative body at will, as they are merely matters of procedure.

  • Judicial power: The judiciary has the power and duty to determine whether an act of Congress or its officials has been made with grave abuse of discretion amounting to lack or excess of jurisdiction.

  • Quo warranto proceeding: A quo warranto proceeding is the proper legal remedy to determine the right or title to a contested public office and to oust an unlawfully holding or exercising such office.

  • Quo warranto proceeding requires the person suing to show a clear right to the contested office or to use or exercise the functions of the office allegedly usurped or unlawfully held.

  • In the absence of specific norms or standards, it cannot be said that illegality or irregularity tainted the assumption and exercise of the powers of an office.

  • Grave abuse of discretion is present when there is a capricious or whimsical exercise of judgment that is equivalent to lack of jurisdiction.