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ERNESTO B. FRANCISCO v. HOUSE OF REPRESENTATIVES

FACTS:

In this case, the Supreme Court of the Philippines addresses a significant constitutional issue arising between two co-equal branches of government—the legislature and the judiciary. The controversy centers on whether the filing of a second impeachment complaint against Chief Justice Hilario G. Davide Jr. falls within the one-year bar provided in the Constitution. This dispute has sparked considerable debate among legal experts and the general public, highlighting the tension inherent in the separation of powers. Specifically, the matter calls into question Article XI of the 1987 Constitution, which governs the accountability of public officers, including the provisions and limitations surrounding impeachment proceedings. On November 28, during the 12th Congress, the House of Representatives adopted the Rules of Procedure in Impeachment Proceedings, which play a crucial role in the present arguments concerning the legitimacy of the second impeachment complaint.

ISSUES:

  1. Whether the filing of the second impeachment complaint against Chief Justice Hilario G. Davide, Jr. with the House of Representatives falls within the one-year bar provided in the Constitution.

  2. Whether the resolution of the issue regarding the second impeachment complaint constitutes a political question.

RULING:

  1. The Supreme Court ruled that the filing of the second impeachment complaint against Chief Justice Hilario G. Davide, Jr. within one year from the previous impeachment complaint violates the one-year bar provided under Article XI, Section 3(5) of the Philippine Constitution.

  2. The Supreme Court held that the issue is not a political question and is within the Court's power to resolve, emphasizing that constitutional provisions are subject to judicial interpretation.

PRINCIPLES:

  • Doctrine of Separation of Powers Each branch of government must operate within its own sphere of authority but with an inherent interdependence and checks and balances to ensure the protection of individual liberties and adherence to the rule of law.

  • Checks and Balances This principle allows each branch of government to check the actions of the others, ensuring a balance of power and preventing any single branch from becoming too powerful.

  • Salus Populi Est Suprema Lex This guiding principle means "the welfare of the people is the supreme law," underscoring that governmental power should be exercised for the benefit and well-being of the populace.

  • Political Question Doctrine The Court clarified that not all instances of governmental action constitute a political question that would preclude judicial review, especially when constitutionally mandated limitations and procedural safeguards are implicated.

  • Impeachment Process Article XI of the Constitution explicitly delineates the procedures and limitations for impeachment, including the provision that no impeachment proceedings shall be initiated against the same official more than once within a period of one year, to prevent abuse of the impeachment power.