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REPRESENTATIVE TEDDY BRAWNER BAGUILAT v. SPEAKER PANTALEON D. ALVAREZ

FACTS:

The case involves the election of the Minority Leader in the House of Representatives. Prior to the opening of the 17th Congress, there were reports about Representative Suarez aiming to be appointed as the "Minority Leader" by the President Duterte's Administration to lead a "cooperative minority" group in the House. Allegedly, some members of the supermajority coalition pretended to be part of the Minority and voted for Suarez to ensure his election.

Before the election of the Speaker, a parliamentary inquiry was conducted regarding the election of the Minority Leader. It was stated that those who vote for the winning Speaker are part of the Majority, those who vote for other candidates belong to the Minority, and those who abstain are considered part of the Minority. Alvarez was elected as the Speaker. However, Suarez was later elected as the Minority Leader by those who did not vote for Alvarez.

In response to this, the petitioners filed a petition for mandamus, seeking to compel the respondents to recognize Representative Baguilat as the Minority Leader and themselves as the legitimate members of the Minority.

ISSUES:

  1. Whether the House of Representatives effectively adopted the new rules proposed by Rep. Fariñas regarding the membership of the Minority and the process of determining the Minority Leader.

  2. Whether the House's deviation from the "long-standing tradition" and the rule that abstaining Members should be deemed independent is constitutional.

  3. Whether the Court has the authority to review the internal proceedings of the House of Representatives in the selection of its officers.

  4. Whether there was any grave abuse of discretion committed by the House of Representatives in the questioned proceedings.

RULING:

  1. Yes, the House of Representatives effectively adopted the new rules proposed by Rep. Fariñas regarding the membership of the Minority and the process of determining the Minority Leader. The unobjected procession of the House during the election of the Speaker and the subsequent election and oath-taking of other officers demonstrate the House's deviation from the "legal bases" claimed by the petitioners. The Journal No. 1 dated July 25, 2016, which is conclusive as to what transpired in Congress, reflects Rep. Fariñas' explanation that those who voted for the winning Speaker would form the Majority and those who did not would form the Minority.

  2. Yes, the House's deviation from the "long-standing tradition" and the rule that abstaining Members should be deemed independent is constitutional. Section 16(1), Article VI of the 1987 Constitution provides that the Speaker of the House shall be elected by a majority vote of its entire membership. It also states that the House may choose officers other than the Speaker as it deems necessary, without specifying the method and manner of choosing such officers. The Supreme Court, in the case of Defensor-Santiago v. Guingona, held that the Constitution is silent on the manner of selecting other officers, giving the House sole control over the process. Thus, the House's deviation from the tradition and rule claimed by the petitioners does not violate the Constitution.

  3. The Court dismissed the petition, ruling that it does not have authority to interfere in the internal proceedings of the House of Representatives absent grave abuse of discretion. In this case, there was no showing of grave abuse of discretion committed by the House of Representatives.

PRINCIPLES:

  • The election of the Speaker of the House of Representatives is the essential and formative step conducted at the first regular session of Congress to determine the constituency of the Majority and Minority.

  • The Journal of the House, in this case, is conclusive as to what transpired in Congress.

  • The House of Representatives has the authority to adopt rules on the membership of the Majority and Minority and the process of determining the Minority Leader, as long as it does not violate the constitutional requirement of a majority vote for the Speaker.

  • The Constitution is silent on the manner of selecting officers other than the Speaker, giving the House sole control over the process.

  • The House of Representatives has the sole authority to determine its own rules of proceedings.

  • Legislative rules, unlike statutory laws, do not have the imprints of permanence and obligatoriness.

  • The Court will not review the wisdom, merits, or propriety of the political departments' actions, but it will strike down acts on the ground of grave abuse of discretion.

  • The Court has the duty and power to pass judgment on whether a branch of government or any of its officials has acted without jurisdiction or in excess of jurisdiction or with grave abuse of discretion.

  • The Court will not interfere with the internal matters of a coequal branch of government absent a showing of grave abuse of discretion.