Francisco v. House of Representatives Digest

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ERNESTO FRANCISCO, JR. VS. THE HOUSE OF REPRESENTATIVES G.R. No. 160261 November 10, 2003 Ccarpio Morales, j.:

Facts: On July 22, 2002, the House of Representatives adopted a Resolution which directed the Committee on Justice "to conduct an investigation, in aid of legislation, on the manner of disbursements and expenditures by the Chief Justice of the Supreme Court of the Judiciary Development Fund (JDF). Then on June 2, 2003, former President Joseph Estrada filed an impeachment complaint against Chief Justice Hilario Davide Jr. and seven Associate Justices. The complaint was endorsed and was referred to the House Committee in accordance with Section 3(2) of Article XI of the Constitution. The House Committee on Justice ruled on October 13, 2003 that the first impeachment complaint was "sufficient in form, but voted to dismiss the same on October 22, 2003 for being insufficient in substance. On October 23, 2003, a second impeachment complaint was filed against Chief Justice Hilario G. Davide, Jr., founded on the alleged results of the legislative inquiry initiated by above-mentioned House Resolution. This second impeachment complaint was accompanied by a "Resolution of Endorsement/Impeachment" signed by at least one-third (1/3) of all the Members of the House of Representatives. Issues: 1. Can the Court make a determination of what constitutes an impeachable offense? 2. Whether or not Sections 15 and 16 of Rule V of the Rules on Impeachment adopted by the 12th Congress are unconstitutional. 3. Whether or not the second impeachment complaint is barred under Section 3(5) of Article XI of the Constitution. Held: 1. No. Such a determination is a purely political question which the Constitution has left to the sound discretion of the legislation. Although Section 2 of Article XI of the Constitution enumerates six grounds for impeachment, two of these, namely, other high crimes and betrayal of public trust, elude a precise definition. 2. Yes. The provisions of Sections 16 and 17 of Rule V of the House Impeachment Rules contravene Section 3 (5) of Article XI as they give the term "initiate" a meaning different from "filing." 3. Yes. Having concluded that the initiation takes place by the act of filing of the impeachment complaint and referral to the House Committee on Justice, the initial action taken thereon, the meaning of Section 3 (5) of Article XI becomes clear. Once an impeachment complaint has been initiated in the foregoing manner, another may not be filed against the same official within a one year period following Article XI, Section 3(5) of the Constitution. In fine, considering that the first impeachment complaint, was filed on June 2, 2003 and the second impeachment complaint filed was on October 23, 2003, it violates the constitutional prohibition against the initiation of impeachment proceedings against the same impeachable officer within a one-year period.

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