MERCY

CONSTITUTIONAL LAW 1
TOPIC: ART. VII CONGRESS AS NATIONAL BOARD OF CANVASSERS

RUY ELIAS C. LOPEZ VS. SENATE OF THE PHILIPPINES (REPRESENTED HEREIN BY THE HON. FRANKLIN DRILON,
PRESIDENT OF THE SENATE) G.R. NO. 163556, JUNE 8, 2004

FACTS:
The case is a petition for prohibition and mandamus seeking to nullify Section 13, Rule VIII of the Rules of the
Joint Public Session of Congress, dated May 28, 2004, creating a Joint Committee which shall preliminarily
canvass the votes of the candidates for President and Vice-President during the May 10, 2004 elections.

ISSUE:
WON Congress committed grave abuse of discretion.

HELD:
No. The Court stresses that it has jurisdiction over the subject matter of this controversy, because the herein
Petition contains sufficient allegations claiming violations of the Constitution. Basic is the rule that jurisdiction
is determined by the allegations of the initiatory pleading, like the complaint or petition. The court deemed
that the petition provide sufficient allegations of violation of the constitution.
Sec. 4, Art. VII expressly provides that to promulgate its rules for the canvassing of the certificates."
In Arroyo v. De Venecia, the Court ruled that it had no power to review the internal proceedings of Congress,
unless there is a clear violation of the Constitution. Likewise, Santiago v. Guingona, held that the Court --
under the doctrine of separation of powers -- has "no authority to interfere" in the "exclusive realm" of a co-
equal branch, absent a showing of grave abuse of discretion. The Court has no authority to restrict or limit the
exercise of congressional prerogatives granted by the Constitution.

However, after careful deliberation on the merits of the Petition and the Comments filed by Senate President
Franklin M. Drilon, Speaker Jose C. De Venecia and the Office of the Solicitor General, the Court resolves to
dismiss the Petition on the ground that it failed to show that Congress gravely abused its discretion in creating
such Joint Committee.
The creation of the Joint Committee does not constitute grave abuse and cannot be said to have deprived
petitioner and the other members of Congress of their congressional prerogatives, because under the very
Rules under attack, the decisions and final report of the said Committee shall be subject to the approval of the
joint session of both Houses of Congress, voting separately. The Petition is dismissed. No costs.